By Edward I. Leeds on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare,Healthcare Providers / SuppliersIn a Memorandum Opinion and Order issued last week, a federal judge in the Eastern District of Texas vacated significant provisions in the regulations under the No Surprises Act. The order addresses the independent dispute resolution (IDR) process that health plans or providers may initiate to resolve differences about how much a health plan should pay for out-of-network [&hellip… Continue Reading »
By Edward I. Leeds and Paige A. Haughton on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary The Consolidated Appropriations Act, 2021 (CAA) requires group health plans and health insurers to submit information regarding the costs of prescription drug costs and other health care services each year to the federal government. This is the ninth briefing in Ballard Spahr’s series on the CAA and health transparency regulations. It was originally published [&hellip… Continue Reading »
By Edward I. Leeds and Jessica M. DuBois on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary The Consolidated Appropriations Act (CAA) requires each group health plan and health insurer with a network of providers to maintain a database on a public website that lists the name, address, specialty, telephone number, and digital contact information for each provider that directly or indirectly participates in the network. These new standards are effective [&hellip… Continue Reading »
By Edward I. Leeds and G'nece Jones on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary To help individuals better understand the costs they will bear for medical care, the Consolidated Appropriations Act (CAA) requires health plan ID cards to include clear information about deductibles and out-of-pocket maximum limitations as well as a telephone number and website address where enrollees can obtain additional information about their coverage. This is the [&hellip… Continue Reading »
By Edward I. Leeds on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / Suppliers,Mental HealthSummary The Departments of the Treasury, Labor, and Health and Human Services jointly issued a report to Congress, fulfilling obligations that they have with regard to the Mental Health Parity and Addiction Equity Act (MHPAEA) and Consolidated Appropriations Act, 2021 (CAA). The report offers valuable insight into the departments’ approach to enforcing the MHPAEA and, [&hellip… Continue Reading »
By Edward I. Leeds and G'nece Jones on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary Health plan vendors sometimes impose contractual restrictions on the disclosure of data that they consider to be confidential or proprietary. A number of new rules aim to foster transparency and require disclosure of pricing and other information that might otherwise be subject to those restrictions. The Consolidated Appropriations Act, 2021 (CAA) prohibits a health [&hellip… Continue Reading »
By Edward I. Leeds and Paige A. Haughton on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary The Consolidated Appropriations Act, 2021 (CAA) requires the disclosure of information to ensure that brokers and certain consultants receive no more than reasonable compensation for their services. This is the fourth briefing in Ballard Spahr’s series on the Consolidated Appropriations Act, 2021 (CAA) and transparency regulations. It was originally was published in November 2021. [&hellip… Continue Reading »
By Edward I. Leeds and G'nece Jones on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary New rules require group health plans and insurers to disclose pricing information in three phases. This is the third briefing in Ballard Spahr’s series on the Consolidated Appropriations Act, 2021 (CAA) and transparency regulations. It was originally published in November 2021. The first installment addressed the new No Surprises Rules. The second focused on Understanding the [&hellip… Continue Reading »
By Edward I. Leeds and Paige A. Haughton on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary This is the second briefing in our series on the Consolidated Appropriations Act, 2021 (CAA) and transparency regulations. It concerns a new rule under the Mental Health Parity and Addiction Equity Act (MHPAEA) that requires health plans to conduct and document an analysis that compares the nonquantitative treatment limitations applicable to benefits for mental [&hellip… Continue Reading »
By Edward I. Leeds and Jessica M. DuBois on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary The following is the first publication in our series on the Consolidated Appropriations Act 2021 (CAA) and transparency regulations. It concerns the rules designed to prevent surprise billings. These No Surprises Rules primarily protect individuals who receive care from an out-of-network provider in situations where the individual has little or no choice about the [&hellip… Continue Reading »
By Edward I. Leeds on Posted in Consolidated Appropriations Act (CAA),Health Plans,Healthcare Providers / SuppliersSummary Health plans now are required to cover the cost of over-the-counter COVID-19 test kits obtained without a health care provider’s prescription or clinical assessment. The new requirement is addressed in a set of FAQs issued January 10 by the U.S. Departments of the Treasury, Labor, and Health and Human Services. The Upshot Plans must meet the [&hellip… Continue Reading »
By Brian M. Pinheiro and Edward I. Leeds on Posted in COBRAThe IRS (with the concurrence of the DOL and HHS) has issued new guidance explaining how the extension of the deadline for paying COBRA premiums will be applied. The extension of deadlines for individuals to elect COBRA and pay for COBRA premiums on account of the COVID-19 pandemic remains in effect. These rules operate by [&hellip… Continue Reading »
By Jean C. Hemphill, Edward I. Leeds and Paige A. Haughton on Posted in Healthcare,HIPAA,Wellness ProgramsThe U.S. Department of Health and Human Services (HHS) has released guidance to address how the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule applies to various entities’ requests for information related to an individual’s COVID-19 vaccination status. HHS emphasized that the Privacy Rule applies only to covered entities, including health plans and most [&hellip… Continue Reading »
By Jean C. Hemphill and Edward I. Leeds on Posted in COBRAThe subsidy for COBRA coverage under the American Rescue Plan Act comes to an end on September 30, 2021. There is no indication at this time that the subsidy will be extended. That means that, beginning October 1, plan and COBRA administrators may start collecting premium payments from individuals who qualified for COBRA because of [&hellip… Continue Reading »
