Clarification on Outbreak Period COBRA Deadlines

By: Jennifer Berman, CEO of MZQ Consulting On October 6, 2021, the Department of Labor, the Department of Treasury, and the Internal Revenue Service jointly released Notice 2021-58. The Notice further clarifies how the “outbreak period” rules impact certain COBRA-related deadlines. As previously reported, in response to the COVID-19 pandemic, deadlines related to COBRA electionsContinue reading “Clarification on Outbreak Period COBRA Deadlines”

Updated Guidance on COVID-19 Vaccines

By: Jennifer Berman, CEO of MZQ Consulting On September 30, 2021 and October 4, 2021, respectively, the Department of Health and Human Services (HHS) and the Department of Labor (DOL) issued updated guidance regarding COVID-19 vaccinations. The HHS guidance specifically relates to recent questions regarding the HIPAA Privacy Rule. The new FAQs provide that HIPAA doesContinue reading “Updated Guidance on COVID-19 Vaccines”

Surprise Bills No More—So What Will Docs Get Paid?

By: Jennifer Berman, CEO of MZQ Consulting As we have previously shared, effective for plan years beginning on or after January 1, 2022, “surprise billing” is prohibited. This means that plan participants can only be billed in-network rates even when they go to out-of-network providers for “protected services.” These protected services include emergency services, servicesContinue reading “Surprise Bills No More—So What Will Docs Get Paid?”

Medicare Part D Coverage Notice Due Date Approaching

By: Lee Susan Spiegel and Megan Diehl The deadline for plan sponsors that offer prescription drug coverage to provide notices of creditable or non-creditable coverage to Medicare-eligible individuals is coming up very soon. These notices need to be provided before October 15, 2021. Creditable coverage means that the plan is expected to cover, on average,Continue reading “Medicare Part D Coverage Notice Due Date Approaching”

Biden Announces Vaccine Mandate and Guidance Issued on Air Ambulance Reporting Requirements and Individual Market Compensation Disclosure

By: Jessica Waltman – Principal, Forward Health Consulting On Thursday, September 9, the Biden Administration released a new COVID-19 Action Plan. The plan states that the Occupational Safety and Health Administration will be issuing a rule requiring all private businesses with 100 or more employees to ensure their employees are fully vaccinated or produce aContinue reading “Biden Announces Vaccine Mandate and Guidance Issued on Air Ambulance Reporting Requirements and Individual Market Compensation Disclosure”

ACA Affordability Percentage Decreased for 2022

Jessica Waltman – Principal, Forward Health Consulting Megan Diehl – Manager, Compliance Consulting, MZQ Consulting The Affordable Care Act (ACA) considers the affordability of employer-sponsored health plans for the purposes of the shared responsibility rules and the premium tax credit (PTC). Affordability depends on a certain percentage of the employee’s household income for the taxContinue reading “ACA Affordability Percentage Decreased for 2022”

Biden Administration Delays Enforcement of New Plan Transparency and Disclosure Requirements

Jessica Waltman – Principal, Forward Health Consulting All health insurance carriers and employers that offer group health coverage to their employees have a wide range of pending compliance responsibilities related to the “No Surprises Act” section of the Consolidated Appropriations Act of 2021 (CAA) and the final health plan transparency rules. However, the Biden Administration justContinue reading “Biden Administration Delays Enforcement of New Plan Transparency and Disclosure Requirements”

New Federal FAQs Address the ACA Preventive Care Rules for HIV Prevention, Medical Management Techniques, and Recommendations that Include a Broad Scope of Care

By: Jessica Waltman, Principal, Forward Health Consulting Federal regulators recently released frequently asked questions (FAQ) guidance about how health insurance issuers and group health plans need to implement the Affordable Care Act’s (ACA) preventive care requirements. This round of FAQs specifically explains how non-grandfathered health insurance plans must provide preventive care benefits to people atContinue reading “New Federal FAQs Address the ACA Preventive Care Rules for HIV Prevention, Medical Management Techniques, and Recommendations that Include a Broad Scope of Care”

National Prohibition on Surprise Billing Effective Starting January 1

On Thursday, July 1, 2021, the Department of Labor (DOL) issued interim final rules governing the prohibition on surprise billing contained in the Consolidated Appropriations Act, 2021 (CAA).  Under the CAA and these new rules, “surprise billing” is prohibited for plan years beginning on or after January 1, 2022.[1] A surprise bill is an unexpectedContinue reading “National Prohibition on Surprise Billing Effective Starting January 1”

IRS Releases Long-Awaited COBRA Subsidy Guidance

Jennifer Berman – CEO, MZQ Consulting Late in the afternoon of May 18, 2021, the IRS released its long-awaited guidance on the COBRA subsidy created by the American Rescue Plan Act of 2021 (ARPA). The guidance, IRS Notice 2021-31, is predominantly in question-and-answer format. It addresses eighty-six specific questions related to the ARPA COBRA subsidy.Continue reading “IRS Releases Long-Awaited COBRA Subsidy Guidance”