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The Departments of Labor, Health and Human Services, and the Treasury issued FAQs about the implementation of the No Surprises Act and transparency provisions of the Consolidated Appropriations Act, 2021 (CAA).
Due to the rapid implementation timeline, the Departments will defer enforcement of some provisions including a price comparison tool, reporting pharmacy benefit and drug costs, and transparency in coverage machine-readable files.
Regulations may not be issued until after January 1, 2022, regarding the interaction of the CAA and the transparency in coverage final rules as well as provider directory and continuity of care requirements. Until then, issuers and plans are expected to use good faith and reasonable interpretation.
The Departments also provided an example of a plan or insurance identification card that would be compliant with the transparency requirements and clarified that grandfathered health plans are generally subject to the CAA’s requirements.
Download the bulletin for more details.
This blog is intended to be a compilation of information and resources pulled from federal, state, and local agencies. This is not intended to be legal advice. For up to the minute information and guidance on COVID-19, please follow the guidelines of the Centers for Disease Control and Prevention (CDC) and your local health organizations.
National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.
