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On April 7, 2025, the Centers for Medicare & Medicaid Services (CMS) issued final Calendar Year 2026 Instructions which introduce a new method for determining whether employer-sponsored prescription drug coverage is considered “creditable” under Medicare Part D. The instructions had previously been released in proposed draft form in January 2025. Background: Employers that offer prescription…
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The following are several leave law updates; including legal challenges to the Missouri Earned Sick Leave law, new implementation dates for Maryland Paid Family Leave Insurance (FAMLI) and upcoming deadlines for Delaware Paid Sick Leave funding contributions: Missouri Earned Paid Sick Leave Despite ongoing litigation and legislative challenges, the start date and notice period for…
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State All-Payer Claims Database Reporting Several states have laws requiring third-party administrators (TPAs), health insurers and other entities to report healthcare eligibility and claims data to the state’s All-Payer Claims Database (APCD). The information collected by the APCD is generally intended to help improve health care quality, reduce costs, and promote transparency. However, requirements vary…
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The Maryland Department of Labor is proposing an extension of the timeline for implementation of the FAMLI program If approved, please note the changes in program implementation dates for both payroll deductions and benefit eligibility: Payroll deductions would begin January 1, 2027 (currently scheduled for July 1, 2025) Benefits would become available on January 1,…
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On January 24, 2025, the U.S. District Court for the District of New Jersey dismissed a putative ERISA class action lawsuit against Johnson & Johnson (J&J). The plaintiff alleged that J&J’s health plan fiduciaries mismanaged the self-funded health plan’s prescription drug benefits, claiming excessive costs for premiums and out-of-pocket expenses. Key Highlights of the Ruling:…
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Maine’s Paid Family and Medical Leave (PFML) Program, established in 2023, is set to provide eligible workers with up to 12 weeks of paid leave starting in 2026, for various reasons listed below. Contributions to the PFML fund began in January 2025, with both employers and employees contributing based on size of the employer. Overview: …
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Effective January 1, 2025, a recently passed Illinois law will impact providers’ ability to provide physical therapy (PT) via telehealth. Illinois licensed physical therapists are prohibited from providing physical therapy services without first conducting an in-person exam. Telehealth PT may only be performed if there is a documented hardship (e.g., geographical, physical, or weather-related conditions).…
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On December 21, 2024, the American Relief Act 2025, a year-end government spending bill, was signed into law. While released drafts of the bill included provisions providing relief that would have allowed high-deductible health plans (HDHPs) to provide pre-deductible coverage for non-preventive telehealth services, this relief was not included in the final version of the…
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The government recently announced changes regarding rules about preventive services and contraceptive coverage for health plans. A previous alert on this topic is included below for reference. Here’s what you need to know: What Happened? The government proposed new rules in February 2023 to balance religious objections to contraceptive coverage while ensuring access to these…
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Both houses of Congress have recently passed, and President Biden is expected to sign, legislation that includes significant changes to Affordable Care Act (ACA) reporting requirements. It is important to note that while this legislation will significantly alter federal ACA reporting requirements, it does not impact state-specific reporting obligations. California, New Jersey, Rhode Island, and…
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