BACKGROUND  updated: May 16, 2022 

The Consolidated Appropriations Act of 2021 (CAA) was signed into law on December 27, 2020 and is a comprehensive set of regulations that includes the No Surprises Act (NSA) and CAA transparency provisions. The No Surprises Act is aimed at protecting health plan members from surprise medical bills from out-of-network providers and facilitating dispute resolutions among providers and health plans. There are several additional provisions included in the NSA, including changes to health plan ID cards, advanced cost estimates and more. Transparency provisions require health insurers and group health plans to create a member-facing price comparison tool and post publicly available machine-readable files that include in and out-of-network charges for covered items and services. 

For fully insured health plans, the insurance carrier is likely responsible for implementing several provisions within the CAA and the Transparency Rule. The chart below provides an overview of each provision along with a brief breakdown of the latest updates from several insurance carriers and how they are handling these changes for their fully insured business. If you are a self-funded client, we will be working with you specifically and your TPA to determine how to handle these updates.*note
This link leads to the machine readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.