Benefits Legal and Administrative Notices and Plan Documents

Federal regulations require employers to provide employees with specific information (“notices”) concerning their rights and responsibilities under a benefits program on an annual basis. These notices cover a variety of topics and may not apply to everyone.

Information

 

Legal and Administrative Notices

This document includes the following Employee Retirement Income Security Act (ERISA) notices: COBRA, HIPAA, WHCRA, CHIP, QLSC, CCDN, GINA.

No Surprise Act (NSA) / Consolidated Appropriations Act, 2021

The U.S. Departments of Health and Human Services (HHS), Labor, and Treasury, and the Office of Personnel Management, issued “Requirements Related to Surprise Billing; Part I,” an interim final rule that will restrict excessive out of pocket costs to consumers from surprise billing and balance billing. Surprise billing happens when people unknowingly get care from providers that are outside of their health plan’s network and can happen for both emergency and non-emergency care. Balance billing, when a provider charges a patient the remainder of what their insurance does not pay, is currently prohibited in both Medicare and Medicaid. This rule will extend similar protections to Americans insured through employer-sponsored and commercial health plans.

Among other provisions, the interim final rule:

  • Bans surprise billing for emergency services. Emergency services, regardless of where they are provided, must be treated on an in-network basis without requirements for prior authorization.
  • Bans high out-of-network cost-sharing for emergency and non-emergency services. Patient cost-sharing, such as co-insurance or a deductible, cannot be higher than if such services were provided by an in-network doctor, and any coinsurance or deductible must be based on in-network provider rates.
  • Bans out-of-network charges for ancillary care (like an anesthesiologist or assistant surgeon) at an in-network facility in all circumstances.
  • Bans other out-of-network charges without advance notice. Health care providers and facilities must provide patients with a plain-language consumer notice explaining that patient consent is required to receive care on an out-of-network basis before that provider can bill at the higher out-of-network rate.

These provisions will provide patients with financial peace of mind while seeking emergency care as well as safeguard them from unknowingly accepting out-of-network care and subsequently incurring surprise billing expenses.

The interim final rule implements the first of several requirements passed with bipartisan support in title I (the “No Surprises Act”) of division BB of the Consolidated Appropriations Act, 2021. The regulations for group health plans, health insurance issuers, and FEHB Program carriers, took effect for plan, policy, or contract years beginning on January 1, 2022. These files can be requested in writing.

For more information go to www.cms.gov, or No Surprises Act Notice



Consolidated Appropriations Act of 2021 - Transparency in Coverage (Price Comparison Tool)

Health plan price transparency helps consumers know the cost of a covered item or service before receiving care. Beginning July 1, 2022, UnitedHealthcare (UHC) and Anthem Blue Cross and Blue Shield have posted pricing information for covered items and services. This includes data on in-network negotiated payment rates and historical out-of-network charges for covered items and services, including prescriptions drugs.

UnitedHealthcare creates and publishes the Machine-Readable Files on behalf of Columbia University. To link to the Machine-Readable Files, please click on the link below:

UHC Transparency in coverage or request the information in writing by calling UnitedHealthcare Customer Service using the number on their ID Card.

Optum Rx:

Optum Rx is accessed through the UHC member portal. When the member clicks on Manage Prescriptions, it takes them to the Optum Rx website. The tool is integrated into the member's profile. It also can be accessed at OptumRx.com. The member does have to sign in.

UHC:

UHC is accessed through the member portal.

Price Comparison Tool

Effective for plan years beginning on or after January 1, 2023, group health plans and health insurance issuers must make an internet-based price comparison tool available to participants, beneficiaries and enrollees. This requirement comes from final rules regarding transparency in coverage (TiC Final Rules) that were issued by the Departments of Labor, Health and Human Services and the Treasury (Departments) in November 2020. According to the Departments, this tool will provide consumers with real-time estimates of their cost-sharing liability from different providers for covered items and services, including prescription drugs, so they can shop and compare prices before receiving care.

Anthem Blue Cross and Blue Shield creates and publishes the Machine-Readable Files on behalf of Columbia University. To link to the Machine-Readable Files, please click on the link below:

Anthem Blue Cross and Blue Shield Transparency in coverage 
(Enter EIN number 13-5598093 to access the reports)

This information is provided in compliance with the Transparency in Coverage Rule (part of the Consolidated Appropriations Act of 2021).  Departments of Health and Human Services, Labor, and the Treasury finalized the Transparency in Coverage Rule that requires health insurers and group health plans to create a member-facing price comparison tool and post publicly available machine-readable files that include in-network negotiated payment rates and historical out-of-network charges for covered items and services, including prescriptions drugs. Data in machine readable files will be updated monthly and made publicly available.

For more information go to Transparency in Coverage on the CMS.gov website.