Blog

On April 10, 2023, the President signed H.J.Res. 7, which ended the COVID-19 national emergency on April 10, 2023, approximately one month earlier than anticipated.  However, prior to the passage of H.J. Res. 7, the DOL and other federal agencies issued guidance in the form of FAQs that indicate an end date of May 11, 2023 for the national emergency […]

On March 3, 2023, federal agencies released Prescription Drug Data Collection (RxDC) Reporting Instructions applicable to the 2022 reference year.  RxDC reporting for the 2022 reference year is due on or before June 1, 2023.    Background The Consolidated Appropriations Act, 2021 (“CAA, 2021”) includes a provision that requires group health plans and health insurance issuers (collectively […]

When the Consolidated Appropriations Act, 2021 (the “CAA”) was enacted on December 27, 2020, it included a provision that prohibits group health plans and health insurance carriers from entering into certain agreements that, either directly or indirectly, restrict the release of certain information related to provider networks and de-identified encounter data, among other things. Such […]

In the course of the last week, we saw two prominent, well-established and significant banks demise. The bank runs caught everyone by surprise because it’s not a credit crisis, like in ’07-’08. Unfortunately, it started with some bad public relations, that resulted in a panic with tens of billions of dollars withdrawn and lead to […]

On February 21, 2023, the IRS released Final Rules amending the existing requirements related to mandatory e-filing of information returns, including Forms 1094-C and 1095-C, among others.  The final rules are effective for all applicable returns due on or after January 1, 2024.  While the final rule requires electronic filing for a number of different information returns, […]

I feel compelled to share lessons in business, life and investing. When there have been major events like the past year in the public equity markets, I find it’s a good time to reflect on observations, mistakes or lessons learned. Like in life, I’m always trying to improve as an investor and take these circumstances […]

On January 30, 2023, President Biden issued a Statement of Administration Policy announcing his intent to extend the COVID-19 national and public health emergencies (collectively, “COVID-19 Emergencies”) set to expire on March 1 and April 11, respectively, until May 11, 2023.  While the COVID-19 Emergencies have not officially been extended at this time, if they are extended […]

On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023 (“CAA, 2023”), into law.  The CAA 2023, which is largely a bipartisan spending bill, sunsets provisions of the Public Health Service Act which permitted large, self-funded, non-federal governmental plans (i.e., self-funded state and local governmental plans) to opt out of the Mental Health Parity and […]

Telehealth Safe Harbor Extended Beyond Calendar Year 2022 On December 29, 2022, the President signed the Consolidated Appropriations Act, 2023 (“CAA, 2023”), into law.  The CAA 2023, which is largely a bipartisan spending bill, includes a new telemedicine safe harbor similar to that which was created under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) […]