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High deductible health plan (“HDHP”) sponsors take note: the Continuing Appropriations Act, 2023 (“CAA23”) temporarily extends the flexibility for HDHPs to provide pre-deductible coverage of telehealth services without affecting the ability to contribute to a HDHP participant’s Health Savings Account (“HSA”).

As we discussed, due to relief first provided in the CARES Act and then extended in Consolidated Appropriations Act, 2022 (“CAA22”), HDHP participants were permitted to receive pre-deductible coverage of telehealth and remote care services during the COVID-19 pandemic without adversely affecting their ability to make or receive contributions to an HSA, except for a few months in the beginning of 2022. This relief was set to expire on December 31, 2022. CAA23 extends this relief through plan years that begin before January 1, 2025.…

Continue Reading Telehealth Safe Harbor Extended

Though much of U.S. government-sponsored pandemic relief has expired as the country approaches it third new year since its first reported cases of COVID-19, pandemic-related law changes exist that continue to impact employee benefit plans, and it is important that plan sponsors and administrators pay close attention to these changes as the new year approaches.

The Employee Benefits Security Administration (EBSA) of the Department of Labor (DOL) and the Department of Treasury and Internal Revenue Service (IRS) issued a notification of relief, effective immediately, that extends certain critical deadlines in health, disability, and other welfare plans (Deadline Relief).[1] This Deadline Relief requires that these plans extend certain deadlines that affect plan participants, beneficiaries, claimants and Consolidated Omnibus Budget Reconciliation Act (COBRA) qualified beneficiaries, by disregarding days during the COVID-19 “Outbreak Period” from counting toward statutory and regulatory timeframes.

The Outbreak Period began on March 1, 2020 and lasts until 60 days after the announced end of the “National Emergency” period for COVID-19 that was declared by the President.

These deadline extensions will impact employer plan sponsors, administrators and insurers.
Continue Reading Important Deadlines Delayed for Health and Welfare Plans due to COVID-19 Emergency: Impacts for Employer Plan Sponsors, Administrators, and Insurers

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The Health Law Insider blog provides insights about health care-related laws and regulations from Stoel Rives’ dedicated team of health care lawyers and industry experts. This blog covers the full spectrum of regulatory and compliance issues faced by the health care industry, including data privacy and security, fraud and abuse, reimbursement, health care transactions, antitrust, taxation, and insurance regulation.