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 | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
On March 10, 2026, the Department of Justice released the first-ever Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (the “Department-wide CEP” or “Policy”), which applies to all non-antitrust corporate criminal cases across the Department. The new policy has been anticipated since December 2025, when Deputy Attorney General Todd Blanche announced the Department’s plans to release a new, single corporate enforcement policy for all criminal matters. According to the Department, the new policy is designed to “help ensure consistency across the Department” and “transparently describe the Department’s policies and decisionmaking.”
Client Alert | 3 min read | 03.12.26
Client Alert | 2 min read | 03.11.26
