Sarah Raaii

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Sarah 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.

Treasury, DOL and HHS Issue Landmark Mental Health Parity Proposed Rule


By , and on Aug 8, 2023
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 (the Departments) recently issued much-anticipated proposed regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) to better ensure that health plans allow access to mental health or substance use disorder benefits as easily as medical or surgical benefits. The proposed regulations...

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Putting Employee Wellness Programs to Work


By and on Jul 19, 2023
Posted In Digital Health, Employee Benefits, Health and Welfare Plans

What are the opportunities and challenges of digital health wellness programs? In a recent discussion, McDermott Partners Scott A. Weinstein and Sarah G. Raaii discussed a wide range of issues, including accessibility to employees, navigating the health plan regulatory landscape, budgetary constraints and the reality of rising healthcare costs. Read more here.

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IRS Issues Reminder that Claims Under Health and Dependent Care FSAs Must Be Substantiated


By , , and on Jun 1, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Internal Revenue Service (IRS) recently issued a Chief Counsel Advice memorandum to remind sponsors of health and dependent care flexible spending arrangements (FSAs) about their responsibility to adequately substantiate claims in order to receive favorable tax treatment under Section 125 of the Internal Revenue Code (the Code). The IRS emphasizes that the standards for...

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Preparing for the End of the COVID-19 Emergency: Deadline Tolling


By , , and on May 18, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April 10, 2023, President Biden signed a resolution moving up the end of the NE to April 10, 2023 (the PHE ended...

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IRS Announces 2024 Limits for Health Savings Accounts, High-Deductible Health Plans and Excepted Benefit HRAs


By and on May 17, 2023
Posted In Employee Benefits, Health and Welfare Plans

Recently, the Internal Revenue Service (IRS) announced (See Revenue Procedure 2023-23) 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 2024. All of the dollar limits currently in effect for 2023 will change for 2024, with the exception of one limit....

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Tri-Agencies Address Preventive Services Coverage in the Wake of Braidwood


By , , and on May 5, 2023
Posted In Employee Benefits, Health and Welfare Plans

The US Departments of Labor, Health and Human Services, and the Treasury (the Departments) have released a series of Frequently Asked Questions (FAQs) in response to Braidwood Mgmt. Inc. v. Becerra, a recent case that invalidated a portion of the Affordable Care Act (ACA) preventive services mandate. The FAQs aim to address inquiries from stakeholders,...

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Preparing for the End of the COVID-19 Emergency: High-Deductible Health Plans and Health Savings Accounts


By , , and on May 3, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration originally announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our prior article for more information). Although the end date of the NE was subsequently advanced to April 10, 2023, by Congressional resolution, the US Departments of Labor, Health and Human...

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Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers


By , , and on Apr 5, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On March 29, 2023, the US Departments of Labor, Health and Human Services, and Treasury (the Departments) issued a set of Frequently Asked...

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Mental Health Parity, Quantitative Treatment Limitations, Employee Assistance Plans and the End of the COVID-19 Emergency


By , , and on Mar 29, 2023
Posted In Employee Benefits, Health and Welfare Plans, Mental Health Parity and Addiction Equity Act

The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). Among other things: The NE and the PHE modified the rules governing financial requirements and quantitative treatment limitations under the Mental Health Parity...

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Telehealth and the End of the COVID-19 Emergency


By , , and on Mar 22, 2023
Posted In Employee Benefits, Health and Welfare Plans

The Biden administration has announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our prior article for more information). In response to the COVID-19 pandemic, lawmakers and agencies made legislative and regulatory changes to expand access to telehealth services for individuals. This article explores...

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