The No Surprises Act which passed under the Consolidated Appropriations Act (“The Act”) includes many provisions that apply to group health plans which go into effect for plan years beginning on or after January 1, 2022. One such provision requires updated medical ID cards, however, guidance is not anticipated until sometime in 2022. In the meantime, plan sponsors are asked to make a good faith effort using a reasonable interpretation of the information provided by the Departments of Treasurer, Labor, and Health thus far.
The Act requires for plan years beginning on or after January 1, 2022, as plans renew, the ID card must include:
- Plan deductibles for network and out-of-network deductible amounts;
- Maximum limits on out-of-pocket costs including network and out-of-network limits, as applicable;
- Phone number and web address for a member to get assistance including help to find a network provider.
Enforcement of the regulation is delayed pending additional guidance, but plans are asked to use a “good faith and reasonable interpretation” of the existing guidance. Diversified Response: Current ID cards already include contact information for assistance to find a network provider and the plan’s copays. However, the cards do not currently include the plan’s deductible or out-of-pocket limit as required by The Act. In order to ensure that our clients are in compliance, Diversified Group will begin meeting the ID card requirement by adding the plan’s deductible and OOP for renewals beginning on or after January 1, 2022. This means that all group members will be issued updated cards upon renewal. The standard ID card charge of $1.60 per card will apply.
Diversified Group will continue to update you as further guidance is released on any aspect of the Consolidated Appropriations Act.