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Group Health Plans and Compliance With the Nonquantitative Treatment Limitations of the Mental Health Parity and Addiction Equity Act | Saul Ewing Arnstein & Lehr LLP
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Medicare Secondary Payer: Issues that Will Impact Work Comp in 2021
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Congress’s passage of the Consolidated Appropriations Act (“CAA”) imposes a series of new recordkeeping and disclosure obligations on plan sponsors, as well as extending and expanding upon COVID-19 related relief. Less than one month into this year, the Department of Labor has also issued regulations and guidance relating to pension plans. Below is a summary of these new requirements.
CHANGES RELATED TO GROUP HEALTH PLANS
Reports on Pharmacy Benefits. The CAA requires group health plans to report certain information related to drug costs for this plan year to the Departments of Health and Human Services, Labor, and the Treasury by December 27, 2021. Subsequent annual reports will be due by June 1st. In addition to general plan information, group health plans must report: a) the 50 most frequently dispensed prescription drugs with the total number of claims for each; b) the 50 most costly prescription drugs with the
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While the future seems uncertain to many in healthcare, there are tell-tale signs of how past opportunities and failures are becoming part of a cycle that will lead us to the future.
In the early 1970s, we saw a new type of healthcare organization emerge called the Health Maintenance Organization. These demonstration projects were encouraged by the government to provoke competition and improve use of resources. Embraced by many communities as a comprehensive solution to both price and quality, HMOs grew rapidly in many markets, attracting the ire of insurance companies who lost large groups of insured and drawing the anger of many physicians who saw charts move from their office to the aligned HMO physician offices. Consumers were drawn to the simplicity of few deductibles, guaranteed access, and comprehensive coverage. Employers were drawn by lower prices but also fewer calls from workers overpayment or access.
Wednesday, January 13, 2021
The Consolidated Appropriations Act (the “Act’”) was signed into law by the president on December 27, 2020, and includes significant health and welfare benefits provisions that affect group health plans and health insurance issuers. The Act is the most comprehensive single piece of legislation to impact group health plans since the Affordable Care Act (ACA).
This
On the Subject summarizes the key provisions of the Act that apply to group health and welfare plan sponsors. The Act includes provisions regarding (1) flexible spending arrangements; (2) surprise medical billing; (3) mental health and substance use disorder benefits; (4) pharmacy benefits reporting; and (5) disclosure of service provider compensation. (For a summary of the Act’s key health provisions, please click here.)
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