
Transparency Reporting Requirements under the CAA
Posted on February 22, 2021 at 1:36 pm
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, […]
The Consolidated Appropriations Act of 2021 Mental Health Parity Expansion – Reporting Requirements
Posted on February 17, 2021 at 5:10 pm
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 […]
Surprise Medical Billing – Federal Law Developments
Posted on November 19, 2019 at 3:02 pm
Employers and employees alike experience the headache and often significant financial burden surprise medical bills (balance billing from an in-network facility where the patient unknowingly receives care from out-of-network providers) present. While some states ban the practice, employers who sponsor or participate in self-funded medical coverage are generally not covered by these laws. Surprise […]
Association Health Plan Developments
Posted on October 22, 2019 at 6:26 pm
A recent court decision calls into question the Department of Labor’s 2018 final rule on association health plans (“AHPs”). On March 28, 2019, the United States District Court for the District of Columbia found that the rule’s interpretation of the term “employer” unreasonable and invalidated several components of the previously issued rule, a rule which […]
How Does Level Funding Compare with Fixed Funded Products?
Posted on February 19, 2019 at 9:00 pm
The large insurance companies including Blue plans (generally referred to as BUCA’s) are offering a version of self-funding we characterize as ”Fixed Funded”. We call them ”Fixed” since there is no options for the self-funded employer to modify the financing arrangement. In real self-funding, the decision to ”Level Fund” is a choice made by employers […]