OPM Publishes FAQ on FEHBP Medical Loss Ratio
Client Alert | 1 min read | 08.30.12
The U.S. Office of Personnel Management (OPM) published a letter and FAQ for federal employees regarding the ACA-mandated Medical Loss Ratio (MLR) for Federal Employees Health Benefits Program (FEHBP) plans in an August 22, 2012 Benefits Administration Letter. The FAQ explains the basic framework of the MLR standard and clarifies that:
- whether an FEHBP plan owes a rebate is determined based on all of a carrier’s line of business (e.g., large group) within a given state;
- any rebated owed by an FEHBP plan shall be paid directly to OPM, the policyholder for all FEHBP plans, as required by FAR §31.201;
- any rebate paid by an FEHBP plan shall be deposited into the contingency reserve of that health plan and shall be used to directly reduce the cost of the next year’s premiums for that plan; and
- FEHBP enrollees will receive a notice from their plan indicating whether the plan did or did not meet the MLR standard.
Insights
Client Alert | 4 min read | 12.04.25
District Court Grants Preliminary Injunction Against Seller of Gray Market Snack Food Products
On November 12, 2025, Judge King in the U.S. District Court for the Western District of Washington granted in part Haldiram India Ltd.’s (“Plaintiff” or “Haldiram”) motion for a preliminary injunction against Punjab Trading, Inc. (“Defendant” or “Punjab Trading”), a seller alleged to be importing and distributing gray market snack food products not authorized for sale in the United States. The court found that Haldiram was likely to succeed on the merits of its trademark infringement claim because the products at issue, which were intended for sale in India, were materially different from the versions intended for sale in the U.S., and for this reason were not genuine products when sold in the U.S. Although the court narrowed certain overbroad provisions in the requested order, it ultimately enjoined Punjab Trading from importing, selling, or assisting others in selling the non-genuine Haldiram products in the U.S. market.
Client Alert | 11 min read | 12.01.25
Client Alert | 5 min read | 12.01.25
