"CMS is extending the public comment deadline for parties to comment on the Draft 2023 Letter to Issuers. The new deadline is Tuesday, February 1, 2022[.]"  MORE >>

"[T]he DOL's MHPAEA Self-Compliance Tool and multiple FAQs have provided guidance on certain questions to ask and general orientation, but stopped short of identifying exactly how and what must be done to satisfy regulators. This concern is exacerbated by the fact that states may have additional and variable expectations, particularly during market conduct exams. Nonetheless, the Report's summaries of common missteps ... provides more grist for iterating an effective comparative analysis model."  MORE >>

"Lawmakers have passed legislation delaying the implementation of Washington state's novel long term care premium tax until July 2023 ... Employers who have already withheld the tax will need to refund it to their employees within 120 days. Those about to run their payroll should take steps to avoid (further) withholding of the tax."  MORE >>

"[T]he report does include guideposts for complying with MHPAEA ... including: [1] Insight into how the Departments chose who to request [comparative analyses (CAs)] from ... [2] A list of the most common NQTLs for which DOL requested CAs. [3] The most common deficiencies in submitted CAs. [4] Common corrections and plan amendments in response to the Departments' enforcement.... [T]he DOL has also focused its efforts on service providers that administer claims for large numbers of plans (so that any resulting changes are passed through to those plans)."  MORE >>

"[T]he Court explained that a plan administrator's reliance on the same evidence to both find a disability and later discredit that disability does not amount to a reliance on significant new evidence. The insurer's about face requires evidence that a 'reasonable mind might accept as adequate to support' its change in decision. " [Roehr v. Sun Life Assurance Co. of Canada, No. 21-1559 (8th Cir. Dec. 27, 2021)]  MORE >>

"How are prices distributed across the hospital locations your employees use? Are most of your employees going to the most expensive facility? Why? If it's because of location, you might need to switch to a carrier that has better prices at that specific hospital or consider creating an incentive for employees to use a different facility. You could partner with the target facility for certain types of standard care and do things like building an in-office clinic or bringing a mammography truck to your office regularly."  MORE >>

34 pages. "Given the broad and substantial set of proposals and significant challenges to fully assess the impact under the short comment time frame, we recommend providing additional comment opportunities before finalization.... [AHIP is] particularly concerned that finalizing many of these policies for the 2023 plan year would result in a significant change from current requirements and plan offerings, placing a significant strain on issuers and providers[.]"  MORE >>

"[1] Do you collect more information than required or retain information longer than necessary, possibly increasing your risk of a breach? [2] Do you know how your data flows internally? Are there safeguards to make sure only those who need to see data can access it? [3] With whom do you share data externally? Should you hold vendors to a particular privacy or security standard? [4] Should you be using encryption or other security measures with respect to your data? [5] What are your procedures in the event of a security breach?"  MORE >>