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Comments to the Department of Health and Human Services on Regulatory Approach to Defining "Essential Health Benefits" — January 31, 2012
The National Business Group on Health, in response to the Department of Health and Human Services' Essential Health Benefits Bulletin, submitted comments supporting a regulatory approach to "essential health benefits" that allows uniform plan administration for self-insured plans and promotes clinical effectiveness, efficiency, and value-based benefit design.

Public Policy Alert — HHS Guidance Proposes to Let Each State Define "Essential Health Benefits" — December 19, 2011
The Department of Health and Human Services (HHS) issued a Bulletin outlining a proposed regulatory approach to defining "essential health benefits" under the Affordable Care Act.

Chart — State Actions to Implement Exchanges — Updated January 9, 2012
A regularly updated chart containing state actions to implement the health insurance exchanges.

Chart — State Actions to Implement the Patient Protection and Affordable Care Act — Updated January 9, 2012
A chart tracking state actions to implement state exchanges, change their tax code to conform to IRS changes Re: adult dependents, and expand Medicaid programs.

Letter to Secretary of Health and Human Services Kathleen Sebelius Clarifying the Business Group's Position on Allowing Stand Alone Vision Plans as a Buy-in Option in the Health Insurance Exchanges — December 14, 2011
The National Business Group on Health (Business Group) sent a letter to HHS Secretary Sebelius clarifying our request that HHS include vision benefits provided by ancillary, or stand-alone plans as a buy-in option in the health insurance exchanges, which we still strongly support, from our recommendations on the Patient Protection and Affordable Care Act's (Affordable Care Act) requirement for pediatric vision services under the essential health benefits package in the final exchange rules.

Comments to the Director of the HHS Center for Consumer Information and Insurance Oversight Recommending HHS Require Transparency of Provider-Specific Price and Quality Information from Exchange Plans — November 21, 2011
The National Business Group on Health sent a letter to the Department of Health and Human Services to ensure the capability of the exchanges and exchange boards to meet the growing consumer demand for provider and facility-specific price and quality information.

Comments to the Department of Health and Human Services (HHS) on the Establishment of Exchanges and Qualified Health Plans — September 26, 2011
The National Business Group on Health submitted a comment letter with our recommendations to the Department of Health and Human Services' (HHS) initial proposed rule on the establishment of exchanges and Qualified Health Plans.

Letter to Secretary of Health and Human Services Kathleen Sebelius to Allow Stand Alone Vision Plans in the Health Insurance Exchanges — September 9, 2011
The National Business Group on Health sent a letter to the Department of Health and Human Services to ensure the capability of the exchanges and exchange boards to meet the growing consumer demand for provider and facility-specific price and quality information.

Public Policy Alert — HHS and Treasury Issue Proposed Regulations on Premium Tax Credit, Exchanges, and Medicaid Eligibility under the Affordable Care Act — August 16, 2011
Recently, the Department of Health and Human Services, the Centers for Medicare and Medicaid Services, and the Internal revenue Service released proposed regulations that provide guidance on the Affordable Care Act's premium tax credit, exchange eligibility rules, and Medicaid eligibility rules.

Public Policy Alert — Department of Health and Human Services (HHS) Releases Initial Rules Giving States Flexibility to Establish Insurance Exchanges — July 21, 2011
The Department of Health and Human Services (HHS) released initial rules which offer the states flexibility in establishing insurance exchanges that includes some important details for employers; however, other details await future guidance.

Letter to the Director of Insurance Exchanges at the Department of Health and Human Services (HHS) Joel Ario with Follow-up Recommendations for the State Insurance — May 9, 2011
The National Business Group on Health sent a letter with follow-up recommendations for the state insurance exchanges from our recent meeting with the Director of Insurance Exchanges at the Department of Health and Human Services (HHS) Joel Ario.

Letter to the Director of the Office of Insurance Exchanges at the Department of Health and Human Services (HHS) Joel Ario Proposing a Model for the State Insurance Exchanges — April 20, 2011
The National Business Group on Health sent an exchange model to the Director of the Insurance Exchange Office at HHS on behalf of large employers, that underscores the need for the state insurance exchanges to aggressively focus on value, promote improvements in the effectiveness and efficiency of care, reduce the total cost of the care for all people and all payers, and make exchange interactions as easy and user-friendly as possible for enrollees.

Comments to Department of Health and Human Services (HHS) on their Initial Guidance to the States on Establishing Exchanges under the Patient Protection and Affordable Care Act — November 23, 2010
The National Business Group on Health submitted comments to HHS' Office of Consumer Information and Insurance Oversight (OCIIO) with recommendations on how to administer the exchanges.

Comments to the Department of Health and Human Services (HHS) on Establishing Exchanges under the Patient Protection and Affordable Care Act — October 4, 2010
The National Business Group on Health submitted comments to HHS' Office of Consumer Information and Insurance Oversight (OCIIO) Regarding Exchange-Related Provisions in the Affordable Care Act.

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Public Policy Alert - IRS Removes Tax Impediment to Immediate Coverage of Dependents to Age 26 — April 28, 2010
The Internal Revenue Service (IRS) removed a tax impediment to immediate coverage of dependents to age 26 and the federal employee plan delays change for dependents of government workers.

Public Policy Alert – Federal Agencies Release Rules for Extending Dependent Coverage to Age 26 — May 11, 2010
The rules clarify allowable employee contribution differentials for adult dependent coverage, prohibited dependent eligibility criteria and employer notification requirements.

Public Policy Alert - Agencies Release Regulations on Grandfathered Plans — June 14, 2010
The Departments of Labor (DoL), Health and Human Services (HHS), and Treasury (IRS) released regulations earlier today on allowable benefit changes group health plans can make while continuing to maintain their grandfathered plan status.

Public Policy Alert - Agencies Modify Regulations on Grandfathered Plans — November 16, 2010
Recently, the Departments of Labor (DoL), Health and Human Services (HHS), and Treasury (IRS) issued rules that modify the previous regulations on grandfathered plans.

Public Policy Alert - Agencies Release Regulations on Annual and Lifetime Limits and Pre-Existing Conditions Exclusions — June 24, 2010
The Departments of Labor (DoL), Health and Human Services (HHS), and Treasury (IRS) released regulations on various aspects of the Patient Protection and Affordable Care Act (PPACA) including rules clarifying allowable annual and lifetime limits and prohibited pre-existing conditions exclusions.

Public Policy Alert - Federal Agencies Release Regulations on Health Plan Requirements for Preventive Services — July 15, 2010
Non-grandfathered plans must cover the preventive services with no cost-sharing.

Public Policy Alert - New Regulations Requiring Coverage of Women's Preventive Services under PPACA— August 2, 2011
Recently, the Health Resources Services Administration (HRSA) released guidelines that require that non-grandfathered group health plans and insurers cover women's preventive services without cost-sharing under the Patient Protection and Affordable Care Act.

Public Policy Alert - Federal Agencies Release Regulations on Plan Internal Appeals and External Review Processes — July 23, 2010
The Departments of Treasury (Internal Revenue Service), Labor (DoL) and Health and Human Services (HHS) issued interim final rules that require non-grandfathered group health plans and health issuers to implement uniform internal appeals and external review processes.

Public Policy Alert - Interim Procedures for External Review and Model Notices for Internal Appeals and External Review — August 24, 2010
The Departments of Treasury (Internal Revenue Service), Labor (DoL) and Health and Human Services (HHS) issued interim guidance on the federal external review process for non-grandfathered group health plans and model notices for internal appeals and external review.

Public Policy Alert - Government Provides Some Relief and Added Flexibility on Internal Appeals Changes and Expands External Review "Safe Harbor" — September 21, 2010
Recently, the Departments of Labor (DoL), Health and Human Services (HHS), and Treasury issued technical guidance in several forms with the goal of easing some of the requirements of the new health care law for health plans, including employer-sponsored health plans.

Public Policy Alert - Federal Agencies Release Amended Rules and New Guidance for Internal Claims and Appeals and External Review Processes under PPACA — June 24, 2011
The Internal Revenue Service (IRS), Department of Labor (DoL) and Health and Human Services (HHS) issued an amendment to the interim final regulations and technical release for internal claims and appeals and external review processes.

• External Review Checklist: Contract and Administration Issues Related to Independent Review Organizations (IROs) — November 10, 2011
  This document provides a checklist of issues for plans to consider when contracting and working with IROs.


• Summary Plan Description (SPD) Checklist: Internal Claims and Appeals and External Review — November 10, 2011
  This document provides a checklist of provisions to include and issues to consider when amending SPDs to include internal claims and appeals and external review requirements under the Affordable Care Act.

Public Policy Alert - Department of Labor Issues Fact Sheet on New Break Time Requirements for Nursing Mothers — July 29, 2010
The Department of Labor (DoL) issued a Fact Sheet providing guidance for employers on the requirements of the Patient Protection and Affordable Care Act's (Affordable Care Act) amendment of the Fair Labor Standards Act (FLSA) that requires employers to provide break times to nursing mothers.

Public Policy Alert - Mini-Med Plan Waiver Guidance Issued — September 7, 2010
The Department of Health and Human Services released guidance for grandfathered "mini-med" or "limited benefit" plans to apply for annual waivers from the health care law's restricted annual limit restrictions when compliance would: result in a significant decrease in access to benefits; or significantly increase premiums.

Public Policy Alert - HHS Restricts the Sale of and Requires Disclosure of Information about Mini-Med Plans — December 10, 2010
Recently, the Department of Health and Human Services (HHS) released new rules that restrict the sale of “mini-med” or “limited benefits“ plans and also require disclosure of plan information to consumers.

Public Policy Alert - Internal Revenue Service Releases Guidance on Use of Health Accounts for Over-the-Counter Drugs in 2011 — September 10, 2010
The Internal Revenue Service (IRS) released guidance on the Patient Protection and Affordable Care Act's (Affordable Care Act) provision that revises the definition of qualified "medical expenses" to exclude over-the-counter (OTC) medicines or drugs, unless prescribed by physicians, for employer-provided plans including health flexible spending accounts (FSAs), health reimbursement arrangements (HRAs) or Health Savings Accounts (HSAs).

Public Policy Alert - IRS Delays W-2 Health Benefits Reporting Requirement — October 13, 2010
Recently, the Internal Revenue Service (IRS) delayed the new health care law's requirement that employers report the cost of health benefits on employees' W-2 forms.

Public Policy Alert - IRS Issues Preliminary Guidance on Upcoming W-2 Reporting Requirement of the Affordable Care Act (ACA) — March 31, 2011
In advance of next year’s requirement that employers report the value of health benefits on employees’ W-2 forms, the IRS provided some guidance yesterday in determining what and how to report it.

Public Policy Alert - IRS Issues Additional Guidance on W-2 Reporting Requirement under the Affordable Care Act — January 5, 2012
The IRS has issued additional guidance on how employers should report the costs of health coverage on Forms W-2.

Public Policy Alert - HHS and Treasury Issue Proposed Regulations on Premium Tax Credit, Exchanges, and Medicaid Eligibility under the Affordable Care Act — August 16, 2011
Recently, the Department of Health and Human Services, the Centers for Medicare and Medicaid Services, and the Internal revenue Service released proposed regulations that provide guidance on the Affordable Care Act's premium tax credit, exchange eligibility rules, and Medicaid eligibility rules.

Public Policy Alert - Federal Government Issues Guidance on Summary of Benefits and Coverage Required of All Plans by Affordable Care Act — August 17, 2011
Today, the Department of Health and Human Services, Department of Labor, and the Internal Revenue Service released proposed regulations that provide guidance on the Affordable Care Act's requirement that group health plans and insurers provide summaries of benefits and coverage ("mini-SPDs") to plan participants and beneficiaries.

Public Policy Alert - The Department of Labor Clarifies More Questions on Health Care Law — October 19, 2010
The Department of Labor (DoL) responded to a number of questions employers have on the grandfathered plan rules, the conflict between rescissions and COBRA, the preventive benefits requirements for non-grandfathered plans and the treatment of dental and vision plans.

Public Policy Alert - Secretary of Health and Human Services (HHS) Issues Rules for Early-Retiree Health Benefits Reinsurance Program — May 5, 2010
HHS recently published the interim final rules (with 30-day comment period) outlining requirements for employers to qualify for reimbursements under the early-retiree health benefits reinsurance program of the health reform law (Patient Protection and Affordable Care Act).

Public Policy Alert - HHS Now Accepting Applications for the Early Retiree Reinsurance Program — June 29, 2010
The Department of Health and Human Services' (HHS) Office of Consumer Information and Insurance Oversight (OCIIO) announced that it will begin accepting applications for approval to submit qualified claims for the Early Retiree Reinsurance Program.

Public Policy Alert - Department of Health and Human Services (HHS) Identifies Claims Not Eligible for Early Retiree Reinsurance Program — September 30, 2010
Recently, HHS issued additional guidance on specific items and services, which Medicare generally does not cover, that HHS will exclude for reimbursement or credit to the $15,000 cost threshold for the Early Retiree Reinsurance Program (EERP).

Public Policy Alert - CMS Issues Additional Guidance for Plan Sponsors on the Early Retiree Reinsurance Program — August 18, 2011
The Centers for Medicare and Medicaid Services (CMS) issued guidance for plan sponsors regarding the Early Retiree Reinsurance Program's reimbursement rules.

Public Policy Alert - Department of Health and Human Services (HHS) Releases Revised Application Form for Early Retiree Reinsurance Program — November 9, 2010
Recently, HHS' Office of Consumer Information and Insurance Oversight (OCIIO) published a revised application with revised "do's and don'ts" for the Early Retiree Reinsurance Program.

Public Policy Alert - Early Retirement Reinsurance Program to End — December 13, 2011
The Centers for Medicare and Medicaid Services issued guidance stating that the Early Retiree Reinsurance Program will end for claims incurred after December 31, 2011.