Health Care Reform

Transparency Disclosures

Non-grandfathered plans must provide certain information to HHS and the public, such as the following:

    • Claims payment policies and practices;
    • Data on specified topics (enrollment, disenrollment, claims denied, and rating practices);
    • Financial disclosures;
    • Information on cost-sharing and payments with respect to out-of-network coverage; and
    • Information on participants' rights under ACA.

      HHS guidance indicated that this requirement will be delayed until at least 2015, but not before guidance is issued.

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      Transparency Hot Topics & FAQs

      • Transparency Reporting
        ACA requires Qualified Health Plans within the Exchanges to submit specified information, such as claims payment policies and practices, enrollment and disenrollment data, financial disclosures, claim denials, rating practices, cost sharing for out-of-network coverage, and enrollee rights, to the Secretary of HHS, state insurance commissioners and the public. In earlier guidance, HHS indicated that Qualified Health Plans generally will not need to provide this information until 2015.

        These transparency requirements also apply to non-grandfathered group health plans, which must make these disclosures to the Secretary of HHS and the public. In the FAQs, the Agencies state that these disclosures will not apply to group health plans any sooner than they apply to Qualified Health Plans.

      American Fidelity Assurance Company does not provide tax or legal advice.


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