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Departments Issue CAA Drug Cost Reporting Requirement Guidance

Quick Facts Starting in 2022, employer-sponsored health plans, health insurance issuers (carriers) and pharmacy benefit managers (PBMs) will be required to submit certain information about prescription drug and healthcare spending to the Departments annually, following the requirements in the Consolidated Appropriations Act (CAA). Reports will include a variety of plan-related information that will be aggregated at the state or market level. The first report is due by December 27, 2022. Background The Department of Health and Human Services (HHS), Department of Labor (DOL) and the Department of the Treasury (collectively “the Departments”) have released an interim final rule …

https://www.epicbrokers.com/insights/caa-drug-cost-reporting-requirement-guidance/

IRS Updates PCORI Fee for Plan Years Ending After October 1, 2021

Quick Facts The Internal Revenue Service (IRS) recently released IRS Notice 2022-4 updating the Patient-Centered Outcomes Research Institute (PCORI) fees for plan years ending on or after October 1, 2021, through September 30, 2022. The payment for the respective plan years will be $2.79 per covered life. Plan sponsors may use one of three methods to determine the average number of covered lives for reporting and paying the PCORI fee. Background On December 21, 2021, the IRS issued Notice 2022-4, providing the adjusted PCORI fees for plan years ending in October 2021 through September 2022. Employers …

https://www.epicbrokers.com/insights/irs-updates-pcori-fee-plan-years-ending-after-october-2021/

Special Compliance Alert: Court Rules OSHA Vaccination Mandate Emergency Temporary Standard Can Move Forward

Updated from the original release on December 21, 2021 Quick Facts On November 4, 2021, the Occupational Safety and Health Administration (OSHA) released its highly anticipated emergency temporary standard (ETS) requiring businesses with 100 or greater employees to mandate their employees to get vaccinated against COVID-19 or wear a mask and test for COVID-19 on at least a weekly basis. The Sixth Circuit Court of Appeals overturned an earlier court ruling, meaning that now private employers with at least 100 employees will need to implement a mandatory vaccine program. OSHA has delayed enforcement of the testing requirement in …

https://www.epicbrokers.com/insights/court-rules-osha-vaccination-mandate-emergency-temporary-standard-can-move-forward/

No Surprises Act Part II Interim Final Rule: Air Ambulance Data Reporting Requirements

… for the two years covered by the reporting requirements in the NSA. Information that must be reported includes: Identifying information for any group health plan, plan sponsor or issuer, and any entity reporting on behalf of the plan or issuer, as applicable; Whether the plan or coverage is a(n) individual plan, large group plan, small group plan, self-funded plan offered by a small employer, self-funded plan offered by a large employer or Federal Employees Health Benefits plan; Date of service; Billing information; Medical billing coding information (i.e., Current Procedural Terminology (CPT) code or Healthcare Common Procedure

https://www.epicbrokers.com/insights/no-surprises-act-air-ambulance-data-reporting-requirements/

Illinois DOL Releases Guidance for Consumer Coverage Disclosure Act

Quick Facts A new disclosure requirement from the Illinois Department of Labor (IDOL) requires employers sponsoring health plans in Illinois to disclose a written list of offered benefits compared to the list of essential health benefits offered by the State of Illinois. According to the rule, because the requirement is on employers, not insurance plans, the disclosure is not preempted by the Employee Retirement Income Security Act (ERISA). The IDOL provided a sample chart of essential health benefits employers can use to fulfill the disclosure requirement. There are penalties for failure to comply. Background On August 27, 2021, the Consumer …

https://www.epicbrokers.com/insights/illinois-dol-releases-guidance-consumer-coverage-disclosure-act/

Challenges in the High Limit Disability Market

One of the most vital coverages for high-income earners is high limit disability protection. With athletes, celebrities, executives, financiers and attorneys making millions of dollars per year, the greatest threat they face to their income stream and lifestyle is a serious disability. And because the major domestic disability carriers (e.g., MetLife, UNUM, etc.) won’t insure more than a million dollars in annual income – the maximum now is $50,000 in monthly coverage at a 60% income replacement – these high earners are forced to look towards the Lloyd’s of London high limit marketplace for the additional coverage …

https://www.epicbrokers.com/insights/challenges-high-limit-disability-market/

HR Technology Trends: Prepare for Outsourced Benefits Administration Service Fee Increases

We’re in the thick of fourth-quarter madness. Open enrollment is always a difficult time for benefits administration and human resources (HR) teams and turnover is common, but issues appear to be different than in previous years. And like many employers, outsourced administration firms are experiencing a shift in their staffing, commonly referred to as “The Great Resignation.” We’re observing these staffing issues and the resultant slow in response times and quality firsthand, and so are our clients. Viewpoints from Virginia Talbot Outsourced administration firms need to balance labor costs and revenue carefully in the best of times …

https://www.epicbrokers.com/insights/hr-technology-trends-outsourced-benefits-administration-service-fee-increases/

Supreme Court Set to Review Section 1557 Disability Discrimination Case

On December 7, 2021, the Supreme Court of the United States (SCOTUS or the Supreme Court) will hear oral arguments in CVS Pharmacy, Inc. v. John Doe. The case involves claims by the plaintiffs, named John Doe to protect their anonymity, against their employer health plans’ pharmacy benefits manager (PBM) CVS Caremark. According to the claimants’ filings, changes to the PBM’s policy on in-network access to specialty drugs disproportionately affects individuals with human immunodeficiency virus (HIV) or acquired immunodeficiency syndrome (AIDS). The Supreme Court accepted the case for review to settle the alleged disparate-impact cause of actions …

https://www.epicbrokers.com/insights/supreme-court-review-section-1557-disability-discrimination-case/