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… the 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 paid out under that same plan. TPAs or insurers typically withhold payments to regain overpayments in cases such as coordination of benefits, subrogation or payment mistakes. 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 Security Act …

On May 18, 2021, the Internal Revenue Service (IRS) issued Notice 2021-31 providing information about the Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage subsidies created by the American Rescue Plan Act (ARPA). Notice 2021-31 addresses a range of issues pertinent to assisting employers, plan administrators and insurers with understanding the COBRA subsidies and associated tax credits. The IRS notice consists of a background explanation of the ARPA COBRA subsidies and a series of 86 questions and answers (Q&As) with some examples. The notice explains and provides guidance on topics such as the calculation of the credit …