Lexology September 24, 2021
Regulations recently promulgated under the Affordable Care Act (“ACA”) and statutory requirements enacted under the Consolidated Appropriations Act, 2021 (“CAA”) both include new transparency requirements applicable to group health plans. Unfortunately, however, there is substantial overlap and inconsistency among those twin transparency rules, creating confusion among plan sponsors and health care providers. Guidance issued in August by the Departments of Labor, Treasury, and Health and Human Services attempts to resolve that confusion.
Duplicative Transparency Requirements – How Did We Get Here?
Final rules implementing the ACA transparency-in-coverage cost-sharing disclosure provisions (referred to as the “Transparency in Coverage Final Rules,” or “TiC Final Rules”) were issued on November 12, 2020, with effective dates ranging from January 1, 2022, through January 1,...
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