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Updates on Provisions of the Transparency in Coverage Rules & Consolidated Appropriations Act

The Departments of Labor, Health and Human Services (HHS) and the Treasury (collectively, the Departments) released the Transparency in Coverage (TiC) Final Rules on November 12, 2020. The TiC Final Rules set forth requirements for group health plans (GHPs) and health insurance issuers in the individual and group markets to disclose cost-sharing information upon request to a participant, beneficiary, or enrollee. The Consolidated Appropriations Act, 2021 (CAA) became law on December 27, 2020. The year-end appropriations bill included ongoing relief and funds relating to the COVID-19 pandemic, permissible changes to Flexible Spending Accounts (FSAs) and Dependent Care …

https://www.epicbrokers.com/insights/updates-on-transparency-in-coverage-rules-caa/

Employer Strategies for COVID-19 Vaccine Policies & Incentives

Quick Facts Employers are generally permitted to require vaccinations so long as reasonable accommodations are offered to those with a disability or religious objection. Employers are generally allowed to provide incentives to employees who obtain the COVID-19 vaccine so long as they follow wellness rules under HIPAA and the EEOC. Generally speaking, limitations or exclusions on eligibility or group medical plans based on vaccination status are not recommended. Background Now that COVID vaccinations are readily available to all but young children, more employers are looking to encourage, and in some cases mandate, employees and their family members to get …

https://www.epicbrokers.com/insights/employer-strategies-for-covid-19-vaccine-policies-incentives/

Health Plan Cost Transparency Update

Quick Facts Recently passed legislation and related regulatory guidance will require insurers and group health plans to provide new information detailing provider reimbursement rates. Beginning in 2022, insurers and health plans must publicly post three reimbursement rate data files. Beginning in 2023, at the request of a participant, plans and insurers must disclose in advance an estimate of the participant’s expected cost-sharing for covered items or services. Most employers who sponsor a group health plan generally do not have access to provider reimbursement rates and will need to rely on their insurance carrier or TPA to provide the …

https://www.epicbrokers.com/insights/health-plan-cost-transparency-update/

Transparency Requirements & Surprise Billing – Agency FAQs Offer Several Delays

… are delayed, with some requirements delayed indefinitely until further guidance is 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 …

https://www.epicbrokers.com/insights/transparency-surprise-billing-agency-faqs-delays/

Amazon and the Continuing Disruption of Primary Care

Primary care physician relationships were once deemed the most sacred in the healthcare system. Long considered the gatekeeper of medical services, plan members built loyal, trusting relationships with these providers, who in turn acted as “quarterbacks” for their patients’ healthcare needs. Like a general contractor overseeing a large construction project, primary care physicians (PCPs) directed members to the appropriate specialists, prescription drugs and hospital systems – and followed up with their patients to ensure medical needs were being met. In fact, the entire health maintenance organization (HMO) model was predicated upon the referral discretion of the PCP; as have more recent …

https://www.epicbrokers.com/insights/amazon-and-the-continuing-disruption-of-primary-care/

San Francisco Makes Updates to the 2022 HCSO Requirements

The San Francisco Health Care Security Ordinance (SF HCSO) requires employers with San Francisco employees to meet specific healthcare expenditure-related obligations. The San Francisco Office of Labor Standards Enforcement (OLSE) updated the SF HCSO website to reflect changes made during the July 19, 2021, San Francisco Board of Directors (the Board) meeting. During the meeting, the City amended the SF HCSO related to telework. On August 6, 2021, the City also announced the updated Health Care Expenditure (HCE) rates for businesses. In addition, the annual employer reporting must be submitted as typically required before the 2022 annual filing deadline …

https://www.epicbrokers.com/insights/san-francisco-makes-updates-to-the-2022-hcso-requirements/

Another Court Rules Against Cross-Plan Offsetting

… As a refresher from a previous article, generally, the Third-Party Administrator (TPA) or insurer of a medical plan may withhold payments to a provider on a new claim to recoup overpayments made to that same provider for other claims. This practice typically occurs in situations such as coordination of benefits, subrogation, or payment mistakes. In addition, cross-plan offsetting occurs when a TPA or insurer, with multiple employer clients, offsets payments to a particular provider for one client’s plan to recoup the overpayments made to that provider from another client’s plan or policy. The Employee Retirement Income …

https://www.epicbrokers.com/insights/another-court-rules-against-cross-plan-offsetting/

Federal Agencies Release New and Additional Guidance Related to COVID-19

Several Federal Agencies have issued COVID-19 (coronavirus) related guidance. On July 26, 2021, the Department of Health and Human Services (HHS) issued guidance addressing how nondiscrimination rules apply to the condition dubbed “long COVID.” On that same day, the Internal Revenue Service (IRS) released Notice 2021-46 to explain further the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium assistance available under the American Rescue Plan Act of 2021 (ARPA). On July 29, 2021, the IRS updated its Frequently Asked Questions (FAQs) on the paid sick and family leave tax credits available under ARPA to clarify the types of employee …

https://www.epicbrokers.com/insights/federal-agencies-release-new-and-additional-guidance-related-to-covid-19/