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New rules published last month likely require your employer health plan to phase-in certain disclosures over a three-year period beginning in one year: 1. January 1, 2022 (three files must be disclosed): For plan years...more
On October 29, 2020, the Department of Health and Human Services (“HHS”), the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) released the Transparency in Coverage Final Rules (the...more
The move by some employer plans to a “reference-based” pricing model has created a need for healthcare providers to develop a strategy to confront payment challenges that these plans create. A prevalent model of...more
Employer-sponsored health plans and health insurers may be required to post online - and to provide participants upon request - a range of pricing and cost-sharing information beginning in 2021. Proposed Affordable Care...more
What is the Annual Maximum Out-Of-Pocket Limit (“MOOP”)? MOOP is the most a participant must pay for covered services under a group health plan in a plan year. After a participant spends this amount on deductibles,...more
Background. These days, almost all employer-sponsored group health plans require an employee (and any dependents) covered under the plan (each are referred to as a “member”) to pay “out-of-pocket” for covered expenses in the...more
On July 17, 2019 the IRS released Notice 2019-45 resolving a preventive care problem that has been plaguing many high deductible health plans (“HDHPs.”). The Affordable Care Act’s free preventive care mandate appears to be...more
On July 17, 2019, the Internal Revenue Service (the “IRS”) released Notice 2019-45 which expands the list of permissible preventive care benefits for high deductible health plan (“HDHP”) purposes. Among other requirements, an...more
As health care costs increase, employers have been exploring new types of health coverage options, one of which is reference-based pricing (RBP). This method typically does not involve a traditional insurance carrier or...more
The chart below compares key provisions of the Affordable Care Act (ACA), the American Health Care Act (AHCA) and the Better Care Reconciliation Act (BCRA). This chart is current as of July 13, 2017, and as of that date,...more
According to consulting and actuarial firm Milliman’s “2015 Milliman Medical Index,” which measures the cost of healthcare for a typical American family of four receiving coverage from an employer-sponsored preferred provider...more
As employers and plans prepare for 2016 open enrollment, they must be sure to address in their benefit design and with their third party vendors the new embedded out-of-pocket maximum limitations on individuals that were...more
Most health plan and health insurance policies include strategies that require persons covered under them to share in the costs that are paid. This strategy, often referred to as cost-sharing, serves two purposes. First, it...more
The Affordable Care Act (the “ACA”) established limitations on the annual out-of-pocket costs that a health plan may impose on a participant. The U.S. Department of Health and Human Services, Department of Labor and the...more
The Departments of Health and Human Services, Labor, and Treasury (collectively, the “Departments”) during the first half of the year issued guidance in the form of Frequently Asked Questions (the “FAQs”) on certain...more