Additional Guidance on New Prescription Drug Reporting Requirement

Ed MacConnell

As previously reported in 2021, Section 204 of the Consolidated Appropriations Act, 2021 (“CAA”) requires plan sponsors of group health plans to submit information annually about prescription drugs and health care spending to Centers for Medicare and Medicaid Services (“CMS”) on behalf of the Departments of Health and Human Services (“HHS”), Labor (“DOL”), and the Treasury (collectively, the “Departments”). The first deadline is December 27, 2022. CMS recently updated guidance related to this reporting requirements that proves some helpful clarification. Have any questions regarding this notice? Please contact your Total Benefit Solutions health insurance specialists today at (215)355-2121.

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Further Guidance Issued on Contraceptive Coverage

Ed MacConnell

On July 28, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, “the Departments”) issued FAQ Part to clarify protections for contraceptive coverage under the Affordable Care Act (the “ACA”). In January 2022, the Departments had issued guidance on the ACA Preventive Care Mandate, including contraception. The Departments issued FAQ Part 54: In response to reports that individuals continue to experience difficulty accessing contraceptive coverage without cost sharing; To clarify application of the contraceptive coverage requirements to fertility awareness-based methods and to emergency contraceptive; and To address federal preemption of state law. Employers sponsoring non-grandfathered group health plans should review the various preventive care requirements effective… Read More

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New Prescription Drug Reporting Requirement

Ed MacConnell

As previously reported in December 2021, Section 204 of the Consolidated Appropriations Act, 2021 (“CAA”) requires plan sponsors of group health plans to submit information annually about prescription drugs and health care spending to Centers for Medicare and Medicaid Services (“CMS”) on behalf of the departments of Health and Human Services (“HHS”), Labor (“DOL”), and the Treasury (collectively, the “Departments”). The first deadline is December 27, 2022. CMS recently updated guidance related to this reporting requirement that provides some helpful clarification. Employers with fully insured or self-funded (includes level funded) group health plans, including grandfathered plans, church plans subject to the Internal Revenue Code, and governmental plans. The term “group… Read More

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Health Insurance Nondiscrimination Rules Small Business Owners Need to Know

Ed MacConnell

Group health plans and tax-favored accounts—including health savings accounts (HSAs), health flexible spending arrangements (health FSAs), and health reimbursement arrangements (HRAs)—are subject to numerous nondiscrimination provisions under federal law. The most common nondiscrimination provisions are described. Please download the entire bulletin for details. As always please contact your Total Benefit Solutions, Inc group account manager at (215)355-2121 with any questions or concerns. This bulletin covers the following topics: Overview General Rules Section 125 Nondiscrimination Rules for Cafeteria Plans Section 105 Nondiscrimination Rules for Self-Insured Plans HIPAA Nondiscrimination Rules Nondiscrimination Rules Related to Medicare-Eligible Individuals Other Nondiscrimination Rules Additional Information

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