News & Analysis as of

Transparency Employer Group Health Plans

Woodruff Sawyer

Agencies Issue Additional FAQs Regarding the Transparency in Coverage Final Rules

Woodruff Sawyer on

On September 27, 2023, the DOL, IRS, and HHS released FAQs About Affordable Care Act Implementation Part 61 (“FAQ Part 61”) which addresses lingering questions about enforcement of the Transparency in Coverage Final Rules...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Bricker Graydon LLP

Departments Roll Back Enforcement Discretion in New Guidance on Transparency in Coverage Rules.

Bricker Graydon LLP on

Well, it was good while it lasted. On September 27th, the Departments issued new FAQs regarding implementation of provisions of The Transparency in Coverage Final Rules (TiC Final Rules). ...more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

Verrill on

Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Mintz - Employment Viewpoints

HHS, Treasury and Labor Issue More Guidance on the No Surprises Act

Title I of Division BB of the Consolidated Appropriations Act, 2021 (the “Act”), and interim final rules issued by the Departments of Health and Human Services, Treasury and Labor (the “Departments”) in July 2021 (see our...more

Jackson Lewis P.C.

New No Surprises Act Guidance -Frequently Asked Questions Bolster Final Rule

Jackson Lewis P.C. on

The No Surprises Act (Act), which establishes protections for health plan participants from surprise medical billing, was passed in late 2020 as part of the 2021 Consolidated Appropriations Act....more

Rivkin Radler LLP

Transparency in Coverage Final Rule Took Effect on July 1

Rivkin Radler LLP on

The Centers for Medicare & Medicaid Services’ Transparency in Coverage Final Rule took effect on July 1, following a six-month delay in implementation to allow payers to come into compliance....more

Groom Law Group, Chartered

July 1 Deadline for Transparency Machine-Readable Files Posting Requirement

As a reminder, on Friday July 1, 2022, with respect to plan or policy years beginning on or after January 1, 2022 through July 1, 2022, group health plans (self-funded and insured) and health insurance issuers are required to...more

Laner Muchin, Ltd.

Reminder: Transparency in Health Coverage Machine Readable Files Must be Posted by July 1, 2022

Laner Muchin, Ltd. on

The Transparency in Coverage Final Rules issued in 2020 require most non-grandfathered insurers and group health plan sponsors to make publicly available online three machine-readable data files with health care pricing...more

FordHarrison

Transparency in Coverage Requirements – Compliance Deadline Approaching

FordHarrison on

Summary: For Health Plans, Machine-Readable Files, containing in-network provider charges and out-of-network allowed amounts and billed charges, must be posted on a public website by July 1, 2022....more

Baker Donelson

Transparency in Coverage Rules

Baker Donelson on

Seeking to improve transparency in the cost of health services, federal actions in the past few years have led to new federal rules and regulations for health systems, benefit administrators, and health plan sponsors. The...more

Williams Mullen

Health Plan Transparency Requirements are Effective Now

Williams Mullen on

The Consolidated Appropriations Act, 2021 (“CAA” or the “Act”) includes several transparency requirements for health plans. Some of these requirements are already in effect for plan years beginning on or after January 1,...more

Bradley Arant Boult Cummings LLP

July 1 Deadline for Health Plan Website Disclosures

The Departments of Labor, Health and Human Services and the Treasury recently issued FAQs About Affordable Care Act Implementation Part 53 (FAQ), which provides additional guidance for non-grandfathered group health plans and...more

Mintz - Employment Viewpoints

Broker and Consultant Disclosures to Group Health Plans under Division BB of the Consolidated Appropriations Act, 2021

Division BB of the Consolidated Appropriations Act, 2021 (“Act”) broadly addresses surprise medical billing and health plan transparency. This post focuses on Section 202 of Division BB (the “Provision”), which establishes...more

Foley & Lardner LLP

Employer Checklist for New Health Plan Price Transparency Rules and CAA

Foley & Lardner LLP on

The effective date is fast approaching for certain provisions of the Consolidated Appropriations Act of 2021 (“CAA”) and related regulations, and the Transparency in Coverage Rule. You can access previous articles written...more

Verrill

You Are Here: A Mall Directory for Healthcare Transparency Requirements

Verrill on

The old adage “you can’t get where you’re going unless you know where you are” has never seemed more true than when applied to the current mélange of healthcare transparency guidance. Fortunately, a fading relic from...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

McAfee & Taft

New health plan guidance regarding transparency regulations and last year’s budget act

McAfee & Taft on

Late last Friday afternoon, the Departments of Labor, Health and Human Services, and the Treasury issued some new frequently asked questions (FAQs) regarding implementation of the transparency in coverage (TIC) regulations...more

McAfee & Taft

More details on transparency rules that apply in 2022 and beyond

McAfee & Taft on

On December 6, 2020, we posted an article titled “RADICAL new transparency rules likely apply to your health plan in one year.” The regulations are a little more than 150 PDF pages long. The following is intended to provide a...more

Nossaman LLP

New Disclosure Requirements for Those that Contract with ERISA Group Health Plans

Nossaman LLP on

Included within the 5539 pages of statutory changes in the Consolidated Appropriations Act, 2021 (the COVID-19 relief bill signed into law at the end of December 2020) are important new “transparency” laws that affect third...more

Faegre Drinker Biddle & Reath LLP

FSA Relief and Significant New Health Plan Requirements Included in Consolidated Appropriations Act of 2021

The Consolidated Appropriations Act of 2021 (Act), enacted on December 27, 2020, contains a number of provisions that may impact the design and administration of employer-sponsored group health plans and flexible spending...more

Morgan Lewis - ML Benefits

Mental Health Parity Transparence: Consolidated Appropriations Act, 2021

As we addressed in our recent LawFlash covering the Consolidated Appropriations Act, 2021 (Act), the Act includes several requirements to enhance group health plan transparency. One provision we wanted to further highlight...more

Alston & Bird

Impact of 2020’s Final Transparency Requirements on Employer-Sponsored Health Plans

Alston & Bird on

On October 29, 2020, the Centers for Medicare and Medicaid Services (CMS) along with the Department of Labor (DOL) and Treasury issued a final rule on price transparency to enable patients to accurately predict health care...more

McAfee & Taft

RADICAL new transparency rules likely to apply to your health plan in one year

McAfee & Taft on

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

Sheppard Mullin Richter & Hampton LLP

Trump Administration Finalizes The Transparency in Coverage Rule

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

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