"While some conflicting details and implementation dates need to be harmonized, many of these rules are effective January 1, 2022, with some effective sooner.... The legal responsibility for [self-funded] plan compliance falls on the plan itself and its fiduciaries, including the employer ... [E]mployers that sponsor self-funded plans should confirm with their TPAs that they will be handling these requirements. Contractual amendments will likely be required." [Updated Aug. 24, 2021]  MORE >>