Practical Compliance

Machine Readable Network and Out of Network Rate Files Enforcement Begins July 1, 2022

The Transparency in Coverage Final Rules (“the TiC Final Rules”) apply to non-grandfathered group health plans and health insurance issuers offering non-grandfathered coverage in the group and individual markets.  The rules require the disclosure of information (in machine readable file format) regarding in-network provider rates, out-of-network allowed amounts, and negotiated rates for covered prescription drugs […]

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Transparency Reporting Requirements under the CAA

The Consolidated Appropriations Act outlines new transparency requirements for covered service providers as it relates to ERISA group health plans.  The Act requires covered service providers, i.e., brokers and consultants to include certain disclosures regarding the receipt of direct and indirect compensation in contracts for services entered, extended, or renewed on or after December 27, […]

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The Consolidated Appropriations Act of 2021 Mental Health Parity Expansion – Reporting Requirements

Health plans and insurers that impose a nonquantitative treatment limitation (NQTL) on mental health or substance use disorder benefits (such as a restriction based on facility type) must perform and document a comparative analysis of the NQTL’s design and application. Other NQTL limit examples include quantitative (i.e., visit limits) and nonquantitative treatment limitations (i.e., preauthorization […]

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DOL Proposed Changes to FMLA Forms

On August 5, 2019, the United States Department of Labor (“DOL”) published a notice seeking public comment on proposed revisions to several model FMLA forms. While use of the DOL forms in FMLA administration is optional for employers, employers who have previously relied on the forms published by the DOL should review the new proposed […]

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