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Employers should stay informed about updates to model notices for group health plans under federal laws. Federal agencies provide and update these notices to aid compliance with changing laws. Here are some key updates to federal model notices in 2023 and 2024 and what forms will be updated in the future.
Expiration Dates
Federal model notices include OMB control numbers and expiration dates. The expiration date does not mean the information is out of date. Agencies get OMB approval for information collections, which must display a control number and expiration date. Agencies request OMB approval extensions periodically, usually for three years. OMB often renews approvals, leading to model notice re-issues with extended expiration dates and no substantive changes.
Action Items
Employers can choose to use optional federal model notices but must include at least the minimum information in the models.
Updates of 2023 and 2024
Health Insurance Exchange Notices
Employers must provide new hires with a "Notice of Coverage Options" about health insurance Exchanges under the Affordable Care Act (ACA). Model notices are available for employers with or without a health plan. The models were recently updated to include affordability thresholds, special enrollment periods, COVID-19 impacts on Medicaid and CHIP eligibility, and Marketplace Employer Coverage Tool information.
CHIP Notice
The Children’s Health Insurance Program Reauthorization Act of 2009 requires annual notice for employers with group health plans in states offering premium assistance subsidies under Medicaid or CHIP. The latest CHIP model notice was current as of January 31, 2024.
No Surprise Billing Notice
For plan years starting January 1, 2022, health plans must publicly disclose balance billing restrictions. Federal agencies require using Version 2 of the model notice for compliance from January 1, 2023. Insurers can contract to fulfill the disclosure for fully insured plans; self-insured plans can partner with others but must ensure compliance.
Summary Annual Report (SAR) Forms
The SAR, a summary of Form 5500 information, must be provided annually by plan administrators within nine months of the plan year's close. Model forms were released for plan years starting in 2023, with no significant changes from the 2022 forms.
- SAR form relating to welfare plans for plan years beginning in 2023 and later
- SAR form relating to pension plans for plan years beginning in 2023 and later
Future Updates
The following documents are intended to be updated in the future and will reflect updated guidance pertaining to the 2023 Culturally and Linguistically Appropriate Services County Data.
- Summary of Benefits and Coverage (SBC) Template and sample completed SBS
- Additional translated version of the SBC and Uniform Glossary
- Model notices for internal claims and appeals and external review
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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.
