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January 1, 2022 Deadline for Plan Sponsors to Post Surprise Billing Notice

The January 1, 2022, deadline is approaching for plan sponsors to post the required notice informing participants of certain changes affecting how medical benefits may be billed under their health plan. This notice is required to be posted by all plan sponsors of group health plans and health insurance issuers offering group or individual health insurance coverage pursuant to the No Surprises Act (Act), which was passed as part of the Consolidated Appropriations Act passed in December 2020.  

model notice has been issued by the Department of Labor and generally must be (i) made publicly available; (ii) posted on the “public website” of the plan or the plan issuer; and (iii) included on each Explanation of Benefits that includes a service subject to the Act. The notice must contain information relating to (i) the restrictions on balance billing in certain circumstances; (ii) applicable state law protections against balance billing (for insured plans only); (iii) the new requirements regarding surprise billing, added by the Act as sections 9816 of the Internal Revenue Code, Section 716 of the Employee Retirement Income Security Act of 1974 and Section 2799A-1 of the Public Health Services Act; and (iv) contact information for relevant federal agencies to report violations.

Plan sponsors of fully-insured group health plans may wish to speak with their insurer about the form and delivery of this notice. Additionally, employers may want to consider whether the notice will be posted with other employment-related notices, as well as whether the notice will be included in other benefit-related communications.

Copyright © 2022 Robinson & Cole LLP. All rights reserved.National Law Review, Volume XI, Number 349
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About this Author

Bruce Barth Benefits lawyer Robinson Cole
Partner

Bruce Barth, chair of the firm's Labor, Employment, Benefits + Immigration Group, as well as the firm’s Employee Benefits + Compensation Team, focuses his practice on the representation of employers and fiduciaries with respect to retirement and welfare benefits, executive compensation, and benefits issues in corporate transactions.

Employee Benefits

Bruce advises clients on the implications of tax, securities, labor, and other laws, including the Employee Retirement Income Security Act (ERISA). Drawing from over 30 years of employee...

860.275.8267
Virginia E. McGarrity Benefits lawyer Robinson Cole
Partner

Virginia McGarrity is a member of the firm's Employee Benefits + Compensation Group, counseling employers, insurance carriers, and service providers on a wide range of complex employee benefits and executive compensation matters.

Retirement Plan Design and Administration

Virginia’s practice addresses a broad array of issues relating to the design, drafting, and operation of qualified and nonqualified defined benefit and defined contribution plans, including 401(k), profit-sharing, multiemployer, employee stock ownership and Section 403(b) and 457(b) plans of...

860.275.8291
Alisha Sullivan Employment lawyer Robinson Cole
Associate

Alisha Sullivan is a member of the firm's Employee Benefits + Compensation Group. She focuses her practice on counseling a wide range of clients on issues arising from the creation and administration of employee benefit plans, including all aspects of plan design and administration, adhering to ERISA, the Internal Revenue Code, and other applicable laws, and plan compliance and correction issues.

Retirement Plan Design and Administration

Alisha's practice addresses a broad array of issues relating to the design, drafting, and operation of qualified and...

860.275.8360
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