In our September 2, 2021 QuickStudy available here, we outlined the various laws governing wellness plans and described how group health plans might structure a premium surcharge for employees who have not received the COVID-19 vaccine to fit within such existing rules. This week, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) issued new Frequently Asked Questions (“FAQs”) that specifically address wellness plan compliance requirements for group health plan premium discounts or surcharges on vaccinated or unvaccinated employees, respectively.

As discussed in our prior post, under the American Rescue Plan Act of 2021, certain individuals who are eligible for COBRA coverage as a result of an involuntary ‎termination of employment or reduction in hours may be eligible...

On April 2, 2021, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) issued Frequently Asked Questions (“FAQs”) related to the implementation of the mental health and substance use disorder parity provisions under the Consolidated Appropriations Act, 2021 (“CAA”) and the Mental Health Parity and Addictions Equity Act (“MHPAEA”).