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On April 11, the Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments) released frequently asked questions (FAQs) on the implementation of the recently enacted Families First Coronavirus Response Act (the FFCRA) and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The FAQs answer stakeholder questions and provide helpful clarifications that will assist health plans, insurers and others in understanding and complying with the new law.
The FFCRA (as amended by the CARES Act) requires group health plans and health insurance issuers to cover the following items and services free of charge:
These items and services must be covered without imposing any cost sharing (including deductibles, copayments and coinsurance). Additionally, prior authorization or other medical management requirements may not be imposed.
The FAQs provide the following helpful clarifications with respect to these coverage requirements:
The FAQs also highlight the CARES Act's amendment to Section 223(c) of the Internal Revenue Code of 1986, as amended (the Code), to allow high-deductible health plans to cover telehealth and other remote care services without a deductible (or with a deductible below the minimum deductible otherwise required). The Departments note that the amendments to Code Section 223 apply generally to all telehealth and other remote care services and are not limited to COVID-19 diagnosis or treatment, and encourage plans to cover such services without cost sharing or other medical management requirements.
For more Day Pitney alerts and articles related to the impact of COVID-19, as well as information from other reliable sources, please visit our COVID-19 Resource Center.
COVID-19 DISCLAIMER: As you are aware, as a result of the COVID-19 pandemic, things are changing quickly and the effect, enforceability and interpretation of laws may be affected by future events. The material set forth in this document is not an unequivocal statement of law, but instead represents our best interpretation of where things stand as of the date of first publication. We have not attempted to address the potential impacts of all local, state and federal orders that may have been issued in response to the COVID-19 pandemic.
Francine Esposito, Rachel Gonzalez and Laura Schuman co-authored the article, "Negotiating a Successor Collective Bargaining Agreement During a Pandemic," for the New Jersey Law Journal.
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Stephen Ziobrowski was quoted in an article, “C-Corp. Conversions Not Attractive To All Pass-Throughs,” published by Law360.
Heather Weine Brochin was quoted in an article, "Confidentiality Disqualifies Harassment Settlement Tax Deductions," published on the Society for Human Resource Management (SHRM) website.