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.
Coverage of COVID-19 Vaccines and the End of the COVID-19 Emergency
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Mar 15, 2023
Posted In Employee Benefits, Health and Welfare Plans
Since the Biden administration announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023, a topic of great debate has been the requirement and the coverage of COVID-19 vaccines. As of March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act has...
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Coverage of COVID-19 Testing and the End of the COVID-19 Emergency
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Mar 8, 2023
Posted In Employee Benefits, Health and Welfare Plans
A key feature of the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) was the government’s ability to provide access and coverage of COVID-19 tests. This resulted in overlapping legislation targeted at providing tests to benefit plan participants for free. With the end of the NE and PHE set for May 11,...
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How Employers Need to Prepare for the End of the COVID Public Health Emergency and National Emergency
By Jacob Mattinson, Sarah Raaii, Alden Bianchi and Teal Trujillo on Mar 2, 2023
Posted In Employee Benefits, Health and Welfare Plans
On January 30, 2023, the Biden administration announced its intention to make final extensions of both the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) through May 11, 2023, at which point both will end. These emergency declarations have been in place for nearly three years and have enabled the government to...
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Proposed Universal Contraceptive Coverage in Response to Roe Reversal
By Alden Bianchi and Sarah Raaii on Feb 14, 2023
Posted In Employee Benefits, Health and Welfare Plans
The US Departments of Health and Human Services, Labor and Treasury (the Departments) recently issued a proposed rule to eliminate a moral exemption to the Affordable Care Act (ACA) contraceptive mandate and establish an “individual contraceptive arrangement” to permit individuals to obtain contraceptive services at no cost in instances in which their employer does not offer...
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No Surprises Act and Three Takeaways on Surprise Billing
By Alden Bianchi and Sarah Raaii on Feb 8, 2023
Posted In Employee Benefits, Health and Welfare Plans
The No Surprises Act (NSA) provides federal protections against surprise billing with respect to emergency services, non-emergency items or services furnished by out-of-network providers at certain in-network healthcare facilities, and air ambulance services furnished by out-of-network providers of air ambulance services. The NSA also establishes that certain federal agencies publish information quarterly about the Federal...
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Prescription Drug Data Reporting: What the “Good Faith Compliance” Extension Really Means for Self-Funded Group Health Plans
By Jacob Mattinson, Sarah Raaii and Alden Bianchi on Jan 11, 2023
Posted In Employee Benefits, Executive Compensation, Health and Welfare Plans, Retirement Plans
We recently reported on an FAQ issued December 23, 2022 (FAQ About Affordable Care Act and Consolidated Appropriations Act, 2021 Implementation Part 56) by the US Departments of Labor, Health and Human Services and the Treasury (collectively, the Departments). The FAQ provides limited, albeit welcome, relief by extending the time for reporting information under the prescription drug data...
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IRS Issues Final Regulations Extending ACA Information Reporting Deadlines, Clarifies Additional ACA Issues
By Jacob Mattinson, Alden Bianchi and Sarah Raaii on Jan 4, 2023
Posted In Employee Benefits, Health and Welfare Plans
The IRS finalized regulations concerning information reporting of health insurance coverage for Code Sections 5000A, 6055 and 6056. The regulations provide an automatic deadline extension for filing ACA forms and an alternate method for providing ACA forms to certain individuals, among other changes. Access the full article.
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Omnibus Bill Extends Medicare Telehealth Flexibilities and HDHP Telehealth Safe Harbor
By Amanda Enyeart, Marshall E. Jackson, Jr., Lisa Schmitz Mazur, Rachel Stauffer, Grayson I. Dimick, Jayda Greco, Abby Higgins, Ashley Ogedegbe and Sarah Raaii on Dec 28, 2022
Posted In Digital Health, Employee Benefits, Health and Welfare Plans
On December 23, 2022, US Congress approved a year-end omnibus legislative package, Consolidated Appropriations Act, 2023 (CAA 2023), which consists of all 12 fiscal year 2023 appropriations bills and numerous other provisions, including health policy changes. The healthcare provisions in this omnibus package extend key Medicare telehealth flexibilities and the temporary telehealth safe harbor for...
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Employers Seek Clarity on Reproductive Healthcare Benefits Litigation Following EEOC Commissioner Filing
By Rachel B. Cowen and Sarah Raaii on Nov 28, 2022
Posted In Benefit Controversies, Employee Benefits, Health and Welfare Plans
Following the US Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, many employers extended travel benefits to women residing in states where abortion or reproductive health procedures may now be unlawful. Recently, US Equal Employment Opportunity Commission (EEOC) Commissioner Andrea Lucas filed a Commissioner’s Charge against at least three companies alleging that doing so...
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Legal Risks Loom For Employers Protecting Abortion Access
By Sarah Raaii on Nov 8, 2022
Posted In Employee Benefits, Health and Welfare Plans
US employers are taking steps to provide abortion access to workers despite threats from anti-abortion activists and conservative lawmakers. In this Law360 article, McDermott’s Sarah Raaii said that “we’re certainly continuing to monitor” threats against employers. “And we’re now in the position — really an unprecedented position for employers — of having to potentially look at 50...
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