Compliance Corner

May 10, 2022

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Podcast Episode 123: Point Solution Programs and Compliance Issues

In this episode, Chase Cannon and Suzanne Spradley look at the recent rise in so-called “point solution programs.” These add-on programs enhance or expand on a group health plan offering and have benefits such as mental health, musculoskeletal, life coaching and fertility. Chase explains some of the compliance challenges that arise from offering the programs, including ERISA, COBRA, and ACA issues when the programs include components of medical care. Next, Chase and Suzanne discuss the challenges surrounding HSA eligibility and taxation, and the two close with general comments on these types of programs.

Periodically, NFP's legal experts make the subject of compliance personal for a wide audience. By breaking down the daunting details of emerging policies and bridging the gap between legislation and what it means for the listener, Chase Cannon and Suzanne Spradley make compliance issues relatable and relevant. Visit our Soundcloud page for the most up-to-date episode.

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May Get Wise Wednesdays – Register Now

Topic: Plan Documents Galore: Understanding the Differences and What’s Required

Plan sponsors must deal with several compliance obligations. Chief among them are the requirements to maintain and potentially distribute plan documents to participants. Join us as we discuss plan documents that are required by the different benefits-related laws and the nuances between them.

Time: May 18, 2022
2:00 to 3:00 p.m. CT (3:00 to 4:00 p.m. ET)

Register Now

This program is pending approval for 1.0 (general) recertification credit hours toward PHR, SPHR and GPHR recertification through the HR Certification Institute. For more information about certification or recertification, visit the HR Certification Institute website at hrci.org.

Note: Those listening to a recorded webinar will not be eligible for credit.

Reminder: Public Disclosure of Provider Reimbursement Rates Begins July 1, 2022

On July 1, 2022, enforcement of the machine-readable file requirement of the Transparency in Coverage (TiC) final rule begins. Under the rule, non-grandfathered group health plans and insurers must publicly post machine-readable files that disclose in-network provider negotiated rates and historical out-of-network allowed amounts and billed charges for plan years beginning on or after January 1, 2022. (Enforcement of the prescription drug rate file requirement is postponed pending regulatory review.)

The files must be in a specified format, updated monthly and posted on a public website accessible to any person free of charge. No conditions can be imposed to access the files, such as establishing a user account or password or submitting personally identifiable information.

Group health plan sponsors should be in consultation with their insurers or third-party administrators to ensure timely compliance with the July 1 deadline. For fully insured plans, the legal obligation can be contractually transferred to the insurer. For self-insured plans, the sponsor remains liable for TiC compliance even if a TPA contractually agrees to assist with the creation and implementation of the files.

For further information, please see:

Transparency in Coverage Final Rule »
FAQs on ACA and CAA, 2021 Implementation »