Small Business Benefits

Federal Mandates

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.

Consolidated Appropriations Act, 2021: Data Due to the Federal Government by June 1, 2024

Attestation Due in December to Federal Government

Employers that sponsor self-funded health benefit plans are required to submit a Gag Clause Prohibition Compliance Attestation (GCPCA) by Dec. 31, 2023, to the federal government. Plans administered by Star Marketing and Administration, Inc., comply with the provision established by the Consolidated Appropriations Act, 2021.

Employers with questions about the attestation or the GCPCA can contact their Client Manager.

Claim Processing Change to Offer Cost Savings

Effective May 17, 2023, we will change the process used to determine provider payments for certain claims submitted to health benefit plans without PPO networks. The change will offer cost savings in most situations for plans and covered employees.

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

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No Surprises Act Overview

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Transparency in Coverage summary

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FAQs About Affordable Care Act And Consolidated Appropriations Act, 2021 Implementation Part 49

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Archived Articles

Consolidated Appropriations Act, 2021: Data due to the federal government by June 1, 2023