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Consolidated Appropriations Act, 2021: Health and Welfare Plan Provisions
Morgan Lewis 
[Guidance Overview] Jan. 6, 2021 "While the provisions in the Act align with calendar year plans, the application of the rules do not align for non-calendar year plans that have closed their plan years for 2020.... The most notable provision of the No Surprises Act is the Independent Dispute Resolution (IDR) process.... There is no minimum rate that must be at issue to access IDR; however, the No Surprises Act does build in some protections to prevent abuse.... [P]lan sponsors should take steps now to ensure that it is fully complying with Mental Health Parity and be prepared to conduct the new required comparative analyses." |
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