Small Business Benefits
Consolidated Appropriations Act, 2021, including the No Surprises Act, and The Transparency in Coverage Rule
The Consolidated Appropriations Act, 20211, including the No Surprises Act 2, ushers in new federal mandates, such as those designed to prevent surprise medical bills. And, as provisions in the Transparency in Coverage Rule3 make healthcare price information publicly accessible, consumers will gain even more information to make informed healthcare decisions.
The changes impact most employer-sponsored, self-funded group health benefit plans. From the beginning, our dedicated team has kept abreast of policy discussions surrounding the need to prevent surprise medical bills and to provide more transparency in healthcare pricing. As requirements from all measures take effect, we will keep brokers updated on important provisions; help plans administered by Star Marketing and Administration, Inc. comply with applicable aspects; and educate members about these sweeping changes.
A timeline for provisions follows for self-funded ERISA plans.
The changes impact most employer-sponsored, self-funded group health benefit plans. From the beginning, our dedicated team has kept abreast of policy discussions surrounding the need to prevent surprise medical bills and to provide more transparency in healthcare pricing. As requirements from all measures take effect, we will keep brokers updated on important provisions; help plans administered by Star Marketing and Administration, Inc. comply with applicable aspects; and educate members about these sweeping changes.
A timeline for provisions follows for self-funded ERISA plans.
Consolidated Appropriations Act, 2021: Data due to the federal government by June 1, 2023
Prescription Drug Data Collection
The Consolidated Appropriations Act, 2021, requires the submission of certain data by June 1, 2023, for the Prescription Drug Data Collection (RxDC) report. The data will show spending on prescription drugs and healthcare services, prescription drugs that account for the most spending, drugs that are prescribed most frequently, prescription drug rebates from drug manufacturers, the required contribution for each employer-sponsored plan in 2022 for covered employees, as well as cost-sharing for covered employees.We will submit data annually for each group. On March 6, 2023, we will send an email to sponsors of self-funded health benefit plans requesting information that is needed to complete the submission accurately.
Transparency in Coverage Rule and No Surprises Act: Effective for plan years beginning on or after 1/1/23 and 1/1/24
Consolidated Appropriations Act, 2021: Data due to the federal government by Dec. 27, 2022
Transparency in Coverage Rule: effective 7/1/22
No Surprises Act provisions: effective for plan years beginning on or after 1/1/22
Provisions with effective date delayed pending federal guidance
Machine-Readable Files
1 The Consolidated Appropriations Act, 2021 was signed into law on Dec. 27, 2020.
2The No Surprises Act is part of the Consolidated Appropriations Act, 2021. The No Surprises Act does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, and retiree-only plans.
3 The Transparency in Coverage rule was released on Oct. 29, 2020, by the U.S. Department of Health and Human Services, the Department of Labor, and the Department of the Treasury. The rule does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, grandfathered plans, and retiree-only plans.
4 Important Open Negotiation and Independent Dispute Resolutions Deadlines
5 The following providers cannot provide notice and consent and their services are subject to the No Surprises Act: radiologists, anesthesiologists, pathologists, neonatologists, assistant surgeons, hospitalists and intensivists. In the case of an emergency, notice may be provided after a patient is stabilized. If notice and consent is not issued/obtained, protections of the No Surprises Act continue to apply.
1 The Consolidated Appropriations Act, 2021 was signed into law on Dec. 27, 2020.
2The No Surprises Act is part of the Consolidated Appropriations Act, 2021. The No Surprises Act does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, and retiree-only plans.
3 The Transparency in Coverage rule was released on Oct. 29, 2020, by the U.S. Department of Health and Human Services, the Department of Labor, and the Department of the Treasury. The rule does not apply to health reimbursement arrangements (HRAs) or other account-based group health plans, short-term, limited-duration insurance, grandfathered plans, and retiree-only plans.
4 Important Open Negotiation and Independent Dispute Resolutions Deadlines
5 The following providers cannot provide notice and consent and their services are subject to the No Surprises Act: radiologists, anesthesiologists, pathologists, neonatologists, assistant surgeons, hospitalists and intensivists. In the case of an emergency, notice may be provided after a patient is stabilized. If notice and consent is not issued/obtained, protections of the No Surprises Act continue to apply.
Plan design availability and/or coverage may vary by state. Plans are administered by Star Marketing and Administration, Inc., and stop-loss insurance and ancillary coverage are provided by Trustmark Life Insurance Company.