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… Negotiated rates and historical prices for prescription drugs furnished by in-network providers. The files must be updated monthly and made publicly available on an insurer’s or plan’s website free of charge. As stated earlier, employers, even self-funded employers, generally do not have access to provider reimbursement arrangements. Fully insured employers will be able to rely on the carrier to produce and make public these files. However, self-funded employers should check with their TPA to ensure that they will be capable of producing the required data on behalf of the employer-sponsored health plan. Advanced Cost …

… provided. However, there are a few requirements that will go into effect in 2022 as originally indicated. Group Health Plan Application & Responsibility The transparency in coverage rules apply to most group health plans, but not grandfathered health plans, excepted benefits (including limited scope dental or vision benefits), or health reimbursement arrangements (HRAs). The CAA requirements apply similarly, but there is no exception for grandfathered health plans. For fully insured plans, the requirements will be handled by the carrier. For self-funded plans, the requirements will generally be handled by third party administrators (TPAs), since employers will not have the information …

… employer should claim the tax credit for their employees covered by the plan. In the case of a merger or acquisition, if the selling entity is responsible to provide COBRA coverage to merger and acquisition qualified beneficiaries, then the selling entity would be entitled to claim the tax credit. Additional questions address tax credit issues for more limited situations such as employees of state agencies, Professional Employer Organization (PEO) relationships, and Multiple Employer Welfare Arrangements (MEWAs). Other Issues Addressed The notice clarifies that individuals with extended continuation eligibility due to disability determinations, second qualifying events, or extensions available under …

… A section is divided into subsections addressing specific topics, including eligibility for the subsidy, reduction in hours, involuntary termination of employment, coverage that is eligible for the subsidy, details regarding the beginning and end of the subsidy period, how to treat extended election periods, coordination of coverage with emergency extension rules, state continuation issues, and significant clarification and guidance on employer payroll tax credits. Significant Guidance Included in Notice 2021-31 Much of the guidance confirms what was already clear from the statute or had been addressed in the 2009 American Recovery and Reinvestment Act (ARRA) COBRA subsidy guidance, but