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The Departments of Labor, Health and Human Services (“HHS”), and the Treasury (the “Tri-agencies”) released their 2022 annual report to Congress on the Mental Health Parity and Addiction Equity Act (“MHPAEA”) on Tuesday, January 25. The Employee Benefits Security Administration (“EBSA”) released an FY 2021 MHPAEA Enforcement Fact Sheet alongside the annual report. Together, the Tri-agencies’ report and EBSA fact sheet provide additional, important information for group health plans and health insurance issuers looking to comply with the 2021 Consolidated Appropriations Act’s (“CAA”) non-quantitative treatment limitation (“NQTL”) comparative analysis requirements. But plans and issuers need additional agency guidance.
Continue Reading 2022 MHPAEA Annual Report Illuminates Tri-agency Review and Enforcement Priorities in a Post-Consolidated Appropriations Act World

On July 16, 2014, the Consumer Information and Insurance Oversight (CCIIO) division of the Centers for Medicare & Medicaid Services (CMS) released an Enrollment Bulletin for the individual markets of Federally-facilitated Exchanges (FFEs) about grace periods for premium non-payment. The Bulletin addresses when grace periods related to terminations for premium non-payment fall across enrollment periods for the next benefit year. Issuers must provide a three-month grace period to Exchange enrollees who receive advance premium tax credits (APTCs), pay at least one month’s premium during the benefit year, and subsequently fail to pay their portion of the monthly premium. If the three-month grace period passes and the enrollee does not pay all outstanding premiums, the issuer must terminate the enrollee’s coverage, retroactive to the last day of the first month of the grace period. All other Exchange enrollees receive grace periods according to state law. The Bulletin explains the following for APTC recipients in FFEs:
Continue Reading CCIIO Issues New Guidance on Grace Periods for Non-payment of Premiums in Exchanges

On August 5, 2013, the Centers for Consumer Information & Insurance Oversight (CCIIO) issued a new Question and Answer (Q&A) on whether Marketplaces will verify consumer income as part of the eligibility process for advance payment of premium tax credits and cost-sharing reductions. The Q&A explained that Marketplaces will verify this information via documentation submitted …

On July 10, 2013, the Center for Medicare and Medicaid Services (CMS) released a “Frequently Asked Question” response regarding CCIIO assessment fees. The question asked “Can States collect assessment fees in their first year of Exchange operations for use in the second year of operations?” The response explained that States can decide to collect assessment …

On June 6, 2013, the Center for Consumer Information and Insurance Oversight (CCIIO) published a new set of frequently asked questions about Cycle III of CMS’s state rate review grant program. Through this program, CMS gives grants to states to support health insurance rate review and increase transparency in health care pricing. Rate review activities …