Reminder: It’s MLR Rebate Time Again!
The ACA requires insurers to submit an annual report to HHS accounting for plan costs. If the insurer does not meet the medical loss ratio standards, they must provide rebates to policyholders. Rebates must be distributed to employer plan sponsors between August 1, 2022, and September 30, 2022. Employers should keep in mind that if they receive a rebate, there are strict guidelines as to how the rebate may be used or distributed.
For more information, please see our recent FAQ.
Reminder: Medicare Part D Notice to Employees Deadline Is October 14, 2022
Employers must notify individuals who are eligible to participate in their medical plan whether the plan’s prescription drug coverage is “creditable” or “non-creditable” as compared to Medicare Part D coverage.
As a reminder, the Medicare Part D notice of creditable coverage should be distributed to employees by October 14, 2022. This notice serves to inform Medicare-eligible individuals of whether or not their employer group coverage is creditable. That information is necessary to help such individuals avoid paying higher premiums (also known as late enrollment penalties) for Medicare Part D coverage.
Employers should consult with their service providers to determine whether their coverage is creditable using either the simplified determination method or actuarial analysis. Also, keep in mind that CMS provides a model notice for employers.
What are the Medicare prescription drug (Part D) disclosure requirements? How does an employer comply?
Coverage Required for Annual Behavioral Health Well Check
September 27, 2022
On August 3, 2022, Gov. Carney signed HB 303 into law. The new law requires insurers to provide coverage for an annual behavioral health well check, which is defined as:
“A pre-deductible annual visit with a licensed mental health clinician with at minimum a masters level degree. The well check must include but is not limited to a review of medical history, evaluation of adverse childhood experiences, use of a group of developmentally appropriate mental health screening tools, and may include anticipatory behavioral health guidance congruent with stage of life using the diagnosis of annual behavioral health well check.”
The coverage may be limited to participating providers and may be subject to a copayment or coinsurance. The new law is effective January 1, 2024.
Early Prescription Refill Reminder Issued
September 27, 2022
On September 23, 2022, the Office of Insurance Regulation issued a notice following Executive Order #22-218, in which Gov. DeSantis declared a state of emergency in 24 counties in the potential path of Hurricane Ian. The notice is directed at all health insurers, health maintenance organizations and other health entities authorized to do business in Florida.
As background, Florida statutes permit early prescription refills if the governor issues an executive order declaring a state of emergency. As a result, insureds in affected areas of the state can fill prescriptions in advance as part of their emergency preparedness.
Accordingly, the memo reminds insurers and other health entities to waive otherwise applicable time restrictions on prescription medication refills and to authorize payment to pharmacies for at least a 30-day supply of any prescription medication, regardless of the date on which the prescription had most recently been filled. Certain limitations and conditions apply in accordance with the applicable provisions of the Florida statutes.
Employers should be aware of the memo and direct any related questions to their carriers.
State Prohibits Cost-Sharing for Monkeypox-related Expenses
September 27, 2022
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