Sarah Raaii
Subscribe to Sarah Raaii's PostsSarah G. Raaii focuses her practice on employee benefits and matters related to health care reform, data privacy and HIPAA compliance, executive compensation, and health and welfare, cafeteria, 401(k), 403(b) and pension plans. Read Sarah Raaii's full bio.
2024 Final Mental Health Parity Regulations: First Impressions
By Alden Bianchi, Jacob Mattinson and Sarah Raaii on Oct 10, 2024
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
Alden Bianchi, Jake Mattinson, and Sarah Raaii recently authored an article in ALM Benefits Pro commenting on the final Mental Health Parity and Addiction Equity Act (MHPAEA) regulations issued last month by the Biden administration. While some of the more objectionable features of the proposed MHPAEA regulations were not finalized, they argue that their basic...
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Webinar Replay: Unpacking the Final Mental Health Parity Regulations
By Alden Bianchi, Jacob Mattinson and Sarah Raaii on Oct 8, 2024
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
During a recent webinar, Alden Bianchi, Jake Mattinson, and Sarah Raaii provided a comprehensive overview of the new MHPAEA rules.
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Plan Sponsors, Insurers, and the Landmark Mental Health Parity Final Rule
By Alden Bianchi, Jacob Mattinson and Sarah Raaii on Sep 19, 2024
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act
The US Departments of the Treasury, Labor, and Health and Human Services recently issued much-anticipated final regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). The newly issued final regulations update the 2013 final regulations principally to reflect the changes to MHPAEA enacted by the Consolidated Appropriations Act, 2021, which requires plans and...
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The Case for the Welfare Plan Fiduciary Committee
By Alden Bianchi, Jacob Mattinson and Sarah Raaii on Aug 13, 2024
Posted In Employee Benefits, Health and Welfare Plans
Recent lawsuits filed against the group health plans of two large US employers underscore the importance of implementing formal welfare benefit plan governance structures that include fiduciary committees comparable to the governance structures employer sponsors of retirement plans routinely adopt. Establishing such committees can help employers reduce litigation risk and ensure compliance with Employee Retirement Income...
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From ERISA to CAA: How Have Employers’ Fiduciary Responsibilities Changed Over Time?
By Sarah Raaii and Alden Bianchi on Jul 23, 2024
Posted In Employee Benefits, Health and Welfare Plans
Health plan fiduciary issues have taken on increased urgency following a new wave of Employee Retirement Income Security Act class action lawsuits filed by plaintiffs’ firms. Sarah Raaii and Alden Bianchi recently joined the Moving to Value Alliance, a healthcare nonprofit, for a podcast episode focused on how group health plan sponsors and third-party service...
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HHS Final Section 1557 Nondiscrimination Regulations: Gender-Affirming Care and the Role of Carriers Under ASO Arrangements
By Sarah Raaii, Alden Bianchi and Scott Kenkel on Jun 5, 2024
Posted In Employee Benefits, Health and Welfare Plans
On April 26, 2024, the US Department of Health and Human Services (HHS) issued a final rule (press release, fact sheet, FAQs) reinterpreting Section 1557 of the Affordable Care Act, which prohibits discrimination on the basis of race, color, national origin, sex, age or disability, or any combination thereof, in a health program or activity, any part of which...
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OPM Urged to Commit to Protecting IVF in Federal Health Insurance
By Sarah Raaii on May 22, 2024
Posted In Employee Benefits, Health and Welfare Plans
Democratic lawmakers recently sent a letter to the US Office of Personnel Management urging the Biden administration to enhance the Federal Employees Health Benefits Program’s in vitro fertilization coverage. The letter comes as some states have signaled an interest in enforcing personhood rights in treatments involving embryos, according to this Federal Times article. “When you...
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IRS Announces 2025 Limits for Health Savings Accounts, High-Deductible Health Plans and Excepted Benefit HRAs
By Jacob Mattinson, Sarah Raaii and Alden Bianchi on May 9, 2024
Posted In Employee Benefits, Health and Welfare Plans
The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2024-25) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs) and excepted benefit health reimbursement arrangements (HRAs) for 2025. All of the dollar limits currently in effect for 2024 will change for 2025, with the exception of one...
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Gender-Affirming Benefits: Best Practices for Group Health Plans
By Sarah Raaii, Alden Bianchi and Scott Kenkel on Mar 5, 2024
Posted In Employee Benefits, Health and Welfare Plans
Group health plan sponsors, third-party administrators and other health plan service providers must navigate a shifting legal landscape as they determine how to offer gender-affirming benefits, including whether − and to what extent − group health plans must cover gender-affirming medical or surgical treatments, especially regarding minors. In this On the Subject, we discuss recent...
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States’ Rights, Trans Protections Collide at Fourth Circuit
By Sarah Raaii on Oct 24, 2023
Posted In Employee Benefits, Health and Welfare Plans
The US Circuit Court of Appeals for the Fourth Circuit recently heard two cases from North Carolina and West Virginia state-run health plans that challenge lower court decisions on coverage exclusions for gender dysphoria treatments. According to this Law360 article, the cases could determine how much health plans can restrict access to gender-affirming care. McDermott...
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