New Health Plan Transparency Requirements

Click here to download this document: Consolidated Appropriations Act and Transparency in Coverage Final Rule – Employee Benefits Provisions

Consolidated Appropriations Act and Final Rule on Health Care Transparency: Employee Benefits Provisions

The Consolidated Appropriations Act, 2021 (CAA), which was signed into law on Dec. 27, 2020, includes many benefits and tax provisions affecting employers, group health plan sponsors, health benefits brokers and health insurance issuers. Some provisions are currently effective, while others begin on future dates.  The provisions related to health plan coverage apply to both insured and self-insured group health plans.

In addition, on October 29, 2020, the Departments of Labor, Health and Human Services and the Treasury issued a Final Rule on Health Care Transparency that imposes new transparency requirements on group health plans and health insurers in the individual and group markets.  These provisions apply to non-grandfathered coverage, including both insured and self-insured group health plans.

On August 20, 2021, the Departments of Labor, Health and Human Services and the Treasury issued Frequently Asked Questions deferring the enforcement of some requirements to a later date, as noted at the end of this document.

This Compliance Overview summarizes the employee benefits provisions relating to surprise medical billing, health plan transparency and mental health parity under the Consolidated Appropriations Act and the Final Rule on Health Care Transparency as well as effective dates and delayed enforcement, where applicable.