Updated No Surprises Act and IDR Guidance

Wendy Lopez

Recent developments in healthcare legislation have brought changes to the No Surprises Act’s independent dispute resolution (IDR) process. Issued by the Departments of Labor, the Treasury, and Health and Human Services (HHS), FAQ Part 62 provides essential updates regarding the qualifying payment amount (QPA) calculation methodology and the disclosure requirements for out-of-network (OON) air ambulance services. Moreover, the federal IDR portal has reopened, streamlining the resolution of billing disputes. The No Surprises Act Overview The No Surprises Act, a part of the Consolidated Appropriations Act, 2021, aims to protect patients from surprise medical bills. It places limits on out-of-network cost-sharing and bans balance billing in various situations, such as emergency… Read More

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Court Vacates Coupon Cost-Sharing Rule

Wendy Lopez

On September 29, 2023, a significant legal development occurred that could affect how health insurance carriers and group health plans handle manufacturer coupons for prescription drugs. The District Court for the District of Columbia vacated a rule issued by the Department of Health and Human Services (HHS) that allowed, but did not mandate, the inclusion of manufacturer coupons in calculating the cost-sharing for health plans. In this blog post, we’ll explore the background of this issue, the 2019 HHS rule, and the subsequent legal decisions that have led to this recent development. HHS’s 2019 Rule In 2019, HHS issued a rule to clarify this matter. The rule stated that plans… Read More

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2024 ACA Affordability Shake-Up: Are You Ready?

Wendy Lopez

Are you ready for some important news regarding the Affordable Care Act (ACA)? The IRS has just released an update that could impact your organization’s healthcare offerings. In this blog post, we’ll break down the latest announcement and what it means for employers and employees alike. If you’re interested in diving deeper, be sure to download our PDF for more information. IRS Announces 2024 ACA Affordability Indexed Amount The IRS recently made an important announcement in Revenue Procedure 2023-29 regarding the Affordable Care Act’s (ACA) affordability indexed amount under the Employer Shared Responsibility Payment (ESRP) requirements. This announcement is significant for employers as it affects the calculation of penalties related… Read More

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What’s New in the 2023 ACA Open Enrollment?

Wendy Lopez

The 2023 Affordable Care Act (ACA) Open Enrollment period is upon us, marking a significant milestone as Health Insurance Marketplaces open their doors for the tenth year. From November 1, 2022, to January 15, 2023, individuals and families have the opportunity to secure comprehensive healthcare coverage. In this blog post, we’ll delve into the key changes and updates for this year’s open enrollment, focusing on insights gathered from the Kaiser Family Foundation’s informative article titled “Nine Changes to Watch in Open Enrollment 2023” [source: www.kff.org/policy-watch/nine-changes-to-watch-in-open-enrollment-2023/]. As the ACA Open Enrollment enters its tenth year, changes abound, ensuring improved access, affordability, and assistance for individuals and families seeking healthcare coverage. Staying… Read More

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IRS Addresses COVID-19 Testing and HDHP Treatment

Wendy Lopez

As a result of the COVID-19 pandemic, high deductible health plans (“HDHPs”) can provide coverage for COVID-19 testing and treatment before the minimum deductible is satisfied without jeopardizing an individual’s ability to have tax-favored contributions made to their health savings account (“HSA”). This relief remains in effect pending future IRS guidance.On June 24, 2023, the IRS issued Notice 2023-37, announcing that this relief will sunset with respect to plan years ending on or before December 31, 2024. In addition, IRS Notice 2023-37 states that HDHPs may continue to provide first-dollar coverage for preventive care with an “A” or “B” rating by the United States Preventive Services Task Force (“USPSTF”), prior… Read More

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