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Insurer not a fiduciary when negotiating rates
  • Hodgson Russ LLP
  • USA
  • February 11 2011

The Court of Appeals for the Sixth Circuit ruled that an insurer was not acting as a fiduciary when it negotiated rates with hospitals that favored its health maintenance organization clients over its self-funded plan clients


New COBRA subsidy rules
  • Hodgson Russ LLP
  • USA
  • March 19 2010

The Temporary Extension Act of 2010 (TEA), signed into law by President Obama on March 2, 2010, includes a number of important changes to the COBRA premium subsidy provisions enacted as part of the American Recovery and Reinvestment Act of 2009 (ARRA


Health reimbursement arrangements and waivers: immediate action required
  • Hodgson Russ LLP
  • USA
  • November 19 2010

Under the Patient Protection and Affordable Health Care Act (PPACA), a group health plan's ability to impose annual limits on essential health benefits is restricted for plan years beginning before January 1, 2014 and prohibited altogether for plan years beginning on or after January 1, 2014


Health care reform update
  • Hodgson Russ LLP
  • USA
  • July 30 2010

Regulations implementing the Patient Protection and Affordable Care Act (PPACA) have been coming out at a steady pace


More health care reform FAQs issued
  • Hodgson Russ LLP
  • USA
  • January 4 2011

Over the past several months DOL, HHS, and the IRS (collectively, the Agencies) have issued a series of frequently asked questions (FAQs) regarding the implementation of the Affordable Care Act


Enforcement of insured plan nondiscrimination rules delayed
  • Hodgson Russ LLP
  • USA
  • January 4 2011

As many employers are by now well aware, the Affordable Care Act imposes nondiscrimination rules on insured non-grandfathered group health plans


Grace period provided for compliance with health plan claims procedures
  • Hodgson Russ LLP
  • USA
  • October 29 2010

Treasury, the Department of Labor, and the Department of Health and Human Services jointly issued a technical release giving group health plans until July 1, 2011, to comply with the new internal claims and appeals procedures required under the Patient Protection and Affordable Care Act (PPACA


Mandatory W-2 reporting of the cost of medical coverage delayed
  • Hodgson Russ LLP
  • USA
  • October 29 2010

Under the PPACA, employers are required to report the cost of employer-sponsored health coverage on their employees' 2011 Forms W-2 (generally issued in early 2012


Plan administrator not obligated to provide benefit accruals for unpaid hours
  • Hodgson Russ LLP
  • USA
  • July 29 2011

Nurse participants in a hospital retirement plan were upset that their unpaid meal breaks, during which they were required to work, and an unpaid 20-40 minute period of patient status review before the official start of their shifts were not counted for benefit purposes in the hospital's retirement plans


Agencies issue amendments to the PPACA claims and appeals processes
  • Hodgson Russ LLP
  • USA
  • July 29 2011

The Treasury, DOL, and the Department of Health and Human Services jointly issued amendments to the interim final rules governing the internal claims and appeals and the external review processes required under the Patient Protection and Affordable Care Act (PPACA