Transparency Requirements

Health plans and insurers will have a little more time to comply with some of the multitude of new requirements under the Consolidated Appropriations Act (“CAA”). On August 20, 2021, the Departments of Labor, Health and Human Services, and the Treasury (the “Departments”) issued an FAQ updating plans and issuers on critical enforcement guidance for several CAA transparency measures. The Departments have acknowledged that plans and issuers are struggling to comply with the litany, and complexity, of transparency requirements the CAA imposes, going so far as to note that compliance with some requirements by initial enforcement dates “is likely not possible.”

Continue Reading Important Enforcement Updates on No Surprises Act and Transparency Requirements