News & Analysis as of

Transparency Health Insurance

McCarter & English, LLP

New Jersey Statutory Update Part II

Below is Part II of our New Jersey Statutory update. As you can see from the below, several statutes were passed imposing requirements on health insurance payers, including new requirements for prior authorization request and...more

Sheppard Mullin Richter & Hampton LLP

CMS Issues Final Rule on Medicaid and CHIP Managed Care Access, Finance, and Quality

On April 22, 2024, the U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) issued a Final Rule (CMS-2439-F), effective July 9, 2024, aimed at advancing healthcare access,...more

Woodruff Sawyer

Agencies Issue Additional FAQs Regarding the Transparency in Coverage Final Rules

Woodruff Sawyer on

On September 27, 2023, the DOL, IRS, and HHS released FAQs About Affordable Care Act Implementation Part 61 (“FAQ Part 61”) which addresses lingering questions about enforcement of the Transparency in Coverage Final Rules...more

Bricker Graydon LLP

Departments Roll Back Enforcement Discretion in New Guidance on Transparency in Coverage Rules.

Bricker Graydon LLP on

Well, it was good while it lasted. On September 27th, the Departments issued new FAQs regarding implementation of provisions of The Transparency in Coverage Final Rules (TiC Final Rules). ...more

Snell & Wilmer

CMS' Transparency-in-Coverage Rule: One Year Later

Snell & Wilmer on

In October 2020, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Transparency in Coverage Rule (“the Rule”), requiring most health insurance plans and issuers offering individual or group coverage to...more

Verrill

Gag Clauses – New Guidance and Litigation Will Inform Compliance

Verrill on

Certain provisions of the Transparency in Coverage Final Regulations and the Consolidated Appropriation Act, 2021 (“CAA”) require group health plans and/or their vendors to report information to federal agencies. On December...more

Manatt, Phelps & Phillips, LLP

[Webinar] State Health Data Organizations: Engines of Market Transparency and Insight - April 12th, 1:00 pm - 2:00 pm ET

Across the country, states are investing in organizations and cross-departmental offices responsible for collecting, managing, integrating and analyzing health system data to provide policymakers, regulators, researchers and...more

Mintz - Employment Viewpoints

HHS, Treasury and Labor Issue More Guidance on the No Surprises Act

Title I of Division BB of the Consolidated Appropriations Act, 2021 (the “Act”), and interim final rules issued by the Departments of Health and Human Services, Treasury and Labor (the “Departments”) in July 2021 (see our...more

Groom Law Group, Chartered

July 1 Deadline for Transparency Machine-Readable Files Posting Requirement

As a reminder, on Friday July 1, 2022, with respect to plan or policy years beginning on or after January 1, 2022 through July 1, 2022, group health plans (self-funded and insured) and health insurance issuers are required to...more

Laner Muchin, Ltd.

Reminder: Transparency in Health Coverage Machine Readable Files Must be Posted by July 1, 2022

Laner Muchin, Ltd. on

The Transparency in Coverage Final Rules issued in 2020 require most non-grandfathered insurers and group health plan sponsors to make publicly available online three machine-readable data files with health care pricing...more

FordHarrison

Transparency in Coverage Requirements – Compliance Deadline Approaching

FordHarrison on

Summary: For Health Plans, Machine-Readable Files, containing in-network provider charges and out-of-network allowed amounts and billed charges, must be posted on a public website by July 1, 2022....more

Ballard Spahr LLP

Technical Guidance Issued on Transparency in Coverage Regulations

Ballard Spahr LLP on

On April 19, 2022, the U.S. Departments of Health and Humans Services, Labor, and Treasury (collectively, the Departments) issued guidance which sets forth two separate safe harbors for group health plans and health insurance...more

Bradley Arant Boult Cummings LLP

July 1 Deadline for Health Plan Website Disclosures

The Departments of Labor, Health and Human Services and the Treasury recently issued FAQs About Affordable Care Act Implementation Part 53 (FAQ), which provides additional guidance for non-grandfathered group health plans and...more

Ballard Spahr LLP

Understanding the New Health Care Transparency Requirements

Ballard Spahr LLP on

Summary - New rules require group health plans and insurers to disclose pricing information in three phases. This is the third briefing in Ballard Spahr’s series on the Consolidated Appropriations Act, 2021 (CAA) and...more

Mitchell, Williams, Selig, Gates & Woodyard,...

National Association of Insurance Commissioners (NAIC) Fall 2021 Meeting Summary

What You Need to Know: Members at the Joint Meeting of the Executive (EX) Committee and Plenary voted to move forward forming the Innovation, Cybersecurity and Technology (H) Committee. Additionally, charges for the new...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Goodwin

HHS, Labor, and Treasury Departments Defer Enforcement of Transparency in Coverage and No Surprises Act Requirements

Goodwin on

The No Surprises Act and Transparency in Coverage final rules go into effect January 1, 2022. Implemented as Titles I and II of Division BB of the Consolidated Appropriations Act, these rules are intended to protect patients...more

McAfee & Taft

New health plan guidance regarding transparency regulations and last year’s budget act

McAfee & Taft on

Late last Friday afternoon, the Departments of Labor, Health and Human Services, and the Treasury issued some new frequently asked questions (FAQs) regarding implementation of the transparency in coverage (TIC) regulations...more

Troutman Pepper

US Chamber of Commerce Files Lawsuit Challenging HHS's Health Plan Price Transparency Rule

Troutman Pepper on

The federal government’s push for greater price transparency in health care has been highly controversial among health care stakeholders. In 2020, the American Hospital Association (AHA) unsuccessfully challenged HHS’s “Price...more

Bass, Berry & Sims PLC

Healthcare Policy Under the Biden Administration: Key Takeaways

Bass, Berry & Sims attorney Angela Humphreys—Chair of the Healthcare Practice and Co-Chair of the Healthcare Private Equity Team—sat down virtually with Paul Keckley—a healthcare policy analyst, industry expert and Managing...more

McAfee & Taft

More details on transparency rules that apply in 2022 and beyond

McAfee & Taft on

On December 6, 2020, we posted an article titled “RADICAL new transparency rules likely apply to your health plan in one year.” The regulations are a little more than 150 PDF pages long. The following is intended to provide a...more

Nossaman LLP

New Disclosure Requirements for Those that Contract with ERISA Group Health Plans

Nossaman LLP on

Included within the 5539 pages of statutory changes in the Consolidated Appropriations Act, 2021 (the COVID-19 relief bill signed into law at the end of December 2020) are important new “transparency” laws that affect third...more

Morgan Lewis - ML Benefits

Mental Health Parity Transparence: Consolidated Appropriations Act, 2021

As we addressed in our recent LawFlash covering the Consolidated Appropriations Act, 2021 (Act), the Act includes several requirements to enhance group health plan transparency. One provision we wanted to further highlight...more

Shumaker, Loop & Kendrick, LLP

Client Alert: District Court of Appeals Upholds Hospital Charges Transparency Rule

The Affordable Care Act of 2010 required that hospitals annually establish and make public a list of its “standard charges.” Health and Human Services (HHS) historically allowed hospitals to comply by posting their charge...more

Foley & Lardner LLP

An Irony of Ironies – The Final ACA Price Transparency Rule

Foley & Lardner LLP on

Some found it somewhat ironic when, only one week before the Acting Solicitor General appeared before the United States Supreme Court to argue that Congress effectively repealed the entire Affordable Care Act (“ACA”) in...more

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