An ongoing commentary from Healthlink Dimensions
Given all of these new requirements, the administration is understandably behind in releasing detailed rules ahead of the January 1, 2022 effective date. Here is a basic summary of the rules released so far.
July 1, 2021 Interim Final Rule key provisions
- Member cost sharing detailed rules
- Qualifying Payment Amount (QPA) calculation method and audit process
- How the QPA is used with both member benefits and provider payments
- Required notice from out-of-network providers regarding NSA rights
August 20, 2021 FAQ was released by the federal administration to identify when rules will be released and any delays to enforcement of current rules or NSA requirements.
- Transparency tool requirements will be delayed until January 1, 2023 and aligned with Transparency in Coverage requirements
- Good Faith Estimates and Advanced Explanation of Benefits (AEOB) will be delayed for all patients that have insurance until rule makers can develop a process for providers to gather and submit the data to health insurers
- Good Faith Estimates will still be required January 1, 2022 for self-pay patients and providers need to be ready to generate these quotes
- ID card changes are confirmed for Jan 1, 2022 effective date
- Provider Directory 90-day validations are still required on Jan 1, 2022 but the FAQ indicates that further rules will be released and insurers given time to comply
September 10, 2021 Interim Final Rule key provisions
- Air ambulance data reporting requirements
- Transparency and disclosure requirements for enrollees to know direct and indirect compensation their insurance broker receives
- Clarifications on federal and state enforcement of NSA regulations
Sept 30, 2021 Interim Final Rule key provisions
- Independent Dispute Resolution defined in detail
- How NSA applies to Federal Employees under the Federal Employees Health Benefits (FEHB) Act
- Rules for good faith estimates for self-pay patients
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