By Roberta Watson, Barry Salkin and Dannae Delano On December 23, 2022, new guidance applicable to group health plans was issued by federal agencies, as described more fully below. The Center for Medicare and Medicaid Services issued updated fee guidance in...
Sophisticated Legal Solutions Boutique-Style Service
Consolidated Appropriations Act
No Surprises in Agencies’ Reproposal of Independent Dispute Resolution Regulations on No Surprise Act Billing Arbitration
By Danae Delano, Roberta Watson and Barry Salkin Last November, we published a law alert regarding the first two rounds of regulatory guidance on the No Surprise Billing portion of the Consolidated Appropriations Act, 2021 (the “CAA”). Since that date, separate...
Department of Labor Announces Temporary Enforcement Policy for Group Health Plan Service Provider Disclosures
By Roberta Casper Watson, Dannae Delano and Barry Salkin The Consolidated Appropriations Act, 2021 (“CAA”) amended Section 408(b)(2) of ERISA to require that providers of brokerage services or consulting services to group health plans who reasonably expect to receive...
Significant Changes to Payroll Protection Program Made Under Consolidated Appropriations Act, 2021
One of the significant components of last year’s Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was the Payroll Protection Program (“PPP”) which was intended to provide relief for struggling small businesses affected by the pandemic. Some of the...