Consolidated Appropriations Act Toolkit
Anthem has created the Consolidated Appropriations Act Toolkit to help you understand the provisions of the bill most applicable to you and your business. Use the Quick Reference to see provision descriptions, effective dates and who needs to take action. The FAQs, articles and other resources provide additional details that will help you prepare and support your clients and employees.
The information contained on this site represents Anthem’s understanding of the Transparency regulation and the Consolidated Appropriations Act. It is not intended to be legal advice. You should consult with your own legal counsel on any issues or questions you have with respect to the Transparency regulation and/or the Consolidated Appropriations Act.
Consolidated Appropriations Act
Quick Reference
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EFFECTIVE DATE: 1/1/2022
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: Passed under the CAA and is intended to protect consumers from certain surprise medical bills from out-of-network providers (OON). It also sets up an independent dispute resolution (IDR) process between the plan and the OON provider to resolve payment disputes.
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EFFECTIVE DATE: 3/31/2023
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: Requires insurers to submit two years of claims data related to air ambulance services to the Secretaries of HHS, Labor and Treasury. Requires the Secretaries to publish a comprehensive report on the cost and claims data submitted.
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EFFECTIVE DATE: 12/27/2021. Reporting to HHS on 7/1/23 and thereafter
WHO NEEDS TO TAKE ACTION: Brokers and health plans
DESCRIPTION: Brokers and consultants of group plans must disclose direct and indirect compensation they receive for the brokerage or consulting services they provide to the group. Health insurers offering individual and short-term coverage must disclose broker compensation to individuals who shop for, purchase and renew coverage.
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EFFECTIVE DATE: 1/1/2022
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: Requires both the in-network and out-of-network deductible and out-of-pocket (OOP) maximum limitations to be included on member ID cards. This provision also requires a telephone number and Internet website address through which individuals may seek consumer assistance information.
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EFFECTIVE DATE: Delayed indefinitely pending further rule-making
WHO NEEDS TO TAKE ACTION: Insurers and plan administrators
DESCRIPTION: Employer health plans or issuers offering individual or group coverage must provide an Advance Explanation of Benefits (AEOB) for scheduled services upon receipt of provider’s good faith estimate or when requested.
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EFFECTIVE DATE: 1/1/2022
WHO NEEDS TO TAKE ACTION: Insurers
DESCRIPTION: Requires health plans to provide in-network coverage for 90 days of continued care to members whose provider or facility leaves the health plan’s network when the member is undergoing treatment for a serious and complex condition, pregnant, receiving inpatient care, scheduled for non-elective surgery, or terminally ill.
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EFFECTIVE DATE: 1/1/2022
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: Employer health plans must create a database on a public website that includes a list of providers and facilities that are in-network. Information must be verified and updated every 90 days.
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EFFECTIVE DATE: 1/1/2022
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: Employer health plans cannot enter into agreements restricting the disclosure of certain information relating to cost and quality. Plans must submit an annual “attestation” to show they are compliant with the requirements.
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EFFECTIVE DATE: 2/10/2021
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: The Mental Health Parity and Addiction Equity Act (MHPAEA) currently requires health plans to apply any non-quantitative treatment limitations (NQTL) in parity between medical benefits and mental health or substance abuse benefits (MH/SUB). If a health plan that provides both medical/surgical benefits and mental health and substance abuse benefits and imposes NQTLs on MH/SUB benefits, the plan has to perform testing and make testing results available to the Tri-Agencies or any state authority.
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EFFECTIVE DATE: 12/27/2022
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: Health plans must annually report information on prescription drug benefits and other health benefit costs to the Tri-Agencies (HHS, Labor and Treasury).
Transparency in Coverage
Quick Reference
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EFFECTIVE DATE: In-network rates and out-of-network charges files delayed to 7/1/22. Prescription drug file delayed indefinitely pending further rule making.
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: Requires insurers/health plans to create and post machine-readable files (MRFs) that can be read by other computer systems, including detailed pricing data regarding:
1. Network negotiated rates for all items and services
2. Historical payments to, and billed charges from, out-of-network providers (must have a minimum of twenty entries to protect consumer privacy) -
EFFECTIVE DATE: 1/1/2023
WHO NEEDS TO TAKE ACTION: Health plans
DESCRIPTION: The Price Transparency tool is an internet tool (paper form upon request) that members can use to see personalized, real-time, cost-share estimates for covered services and items, including pharmacy for 500 designated items/services in 2023 and all items/services in 2024. Due to the duplication of the CAA Cost Comparison Tool requirement. The CAA Cost Transparency Tool requirement is a similar tool that now aligns with the Transparency in Coverage timeline. The CAA requirement is being merged into the member cost tool requirements of the Transparency in Price regulation.
Meaningful Transparency
Read our position paper Meaningful Transparency to see how we are taking transparency beyond cost, addressing consumer needs to provide a personalized, value-driven experience.
Frequently Asked Questions
Transparency in Coverage and Consolidated Appropriations Act FAQ
Transparency in Coverage and Consolidated Appropriations Act FAQ
JAA/MCS
Broker/Agent Disclosure of Compensation Disclosure FAQ
Related Articles
Broker Compensation
Disclosure
Gag clause compliance requirements
Impact to member
ID cards
Machine-readable files
available July 1, 2022
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