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On November 17, 2021, the Internal Revenue Service (IRS), U.S. Department of Labor (DOL) and Health and Human Services (HHS) (collectively, the “Departments”), with the Office of Personnel Management (OPM), issued interim final regulations (IFR) to provide guidance regarding health care transparency provisions of the Consolidated Appropriations Act, 2021 (CAA). The IFR will apply to group health plans effective December 27, 2021. However, the Departments have announced a non-enforcement policy for the first year of applicability.
In late 2020, Congress enacted the CAA, which added general transparency obligations on group health plans regarding accuracy of provider directories, information to be placed on insurance ID cards and requirements to ensure continuity of patient care when a provider switches from in-network to out-of-network during a course of treatment. The CAA also contained provisions targeting disclosure of plan pricing and cost information including specific requirements regarding prescription drug costs. The IFR specifically addresses plan obligation to report this information annually to the Departments.
Download the full advisor to learn what to report, who must report, and when reports Departments are due.