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Health & Welfare Plans Newsletter

December 27, 2022

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[Official Guidance]

Text of Agency FAQs About No Surprises Act Implementation: Good Faith Estimates for Uninsured (or Self-Pay) Individuals, Part 4 (PDF)

"Q1: How can Federally Qualified Health Centers (FQHCs) and other providers and facilities that offer sliding fee discounts comply with GFE requirements? ... Q2: How can providers comply with the GFE requirements if they do not expect to bill uninsured (or self-pay) individuals for scheduled (or requested) items or services? ... Q3: When would an abbreviated GFE be subject to the PPDR process, and how would that process apply? ... Q4: What types of contact information should providers and facilities include in a GFE for uninsured (or self-pay) individuals?"  MORE >>

U.S. Department of Health and Human Services [HHS]; U.S. Department of Labor [DOL]; and U.S. Treasury Department

[Guidance Overview]

Tri-Agencies Issue Welcome Relief on Prescription Drug Reporting

"[T]he Departments announced two important pieces of relief ... [1] The Departments will not take enforcement action against a plan or issuer that uses a good faith, reasonable interpretation of the regulations and the reporting instructions in making its submission for the 2020 and 2021 plan years, and [2] The Departments will permit a grace period until January 31, 2023, for the 2020 and 2021 submissions due on December 27th."  MORE >>

Proskauer

[Guidance Overview]

Omnibus Bill Extends HDHP Telehealth Safe Harbor

"Congress has extended the safe harbor period again, now through December 31, 2024. This extension will allow HDHPs with plan years beginning after December 31, 2022, and before January 1, 2025, to ... continue coverage of telehealth services without constituting disqualifying coverage for HSA contributions."  MORE >>

McDermott Will & Emery

[Guidance Overview]

CAA 2023 Includes Two-Year Extension of HSA Telehealth Relief

"The CAA 2023 extends for a second time the HSA relief permitting high deductible health plans (HDHPs) to provide first-dollar telehealth and other remote care services for plan years beginning after December 31, 2022 and before January 1, 2025 (i.e., the 2023 and 2024 plan years for employers with a calendar plan year). Those telehealth or other remote care services do not need to be preventive or related to COVID to qualify for the relief."  MORE >>

Newfront

Can Health Systems Compete with Disruption from Pharmacy Retail Giants?

"Recent moves from CVS and Walgreens show that the pharmacy retail giants are making leaps into healthcare spaces they've never touched -- but hospitals aren't sweating yet.... How are hospitals and health systems responding to these changes from pharmacy giants?"  MORE >>

Sharyl Attkisson via Becker's Hospital Review

How Flexible Benefits Can Help Companies Meet New Employee Demands

"Flexible benefits and professional development programs have a direct impact on the resources available to employees, how they work, and their job responsibilities. But flexibility has a more fundamental effect on your workforce -- a healthier culture."  MORE >>

HR Daily Advisor

Can an Employer Offer Health Insurance to Its Board's Directors?

"Covering non-employees (whether directors, board members or owners) under a company's benefit programs is likely to raise compliance concerns (assuming the written plan eligibility rules allow non-employees to enroll in coverage). For one, it is unclear whether a Multiple Employer Welfare Arrangement (MEWA) is created when health or other welfare benefits are provided to non-employee directors."  MORE >>

Willis Towers Watson

2021 U.S. National Health Expenditures

"institutional services make the largest share of health care spending. Specifically, hospital care made up 31% of cost, a broad 'other' category 23%, physician services 20% and prescription drugs 9%. Administrative costs from government and health insurers made up 7% of costs which is relatively high by international standards."  MORE >>

Healthcare Economist

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Last Issue's Most Popular Items

CAA 2023 Includes HSA Telehealth Relief

Groom Law Group

HHS Issues Proposed 2024 Benefit and Payment Parameters, Announces Adjusted Annual Limitation on Cost-Sharing for 2024 Benefit Year

Thomson Reuters / EBIA

Summary of Provisions of HHS' Proposed 2024 Notice of Benefit and Payment Parameters and Other Key Regs (PDF)

Wakely Consulting Group

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BenefitsLink Retirement Plans Newsletter, ISSN no. 1536-9587.

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