We asked our readers what the biggest hot button issues are that are on their radar this year as we prepare for Q4 craziness?
|Glitch guidance
I anticipate that we will see greater utilization of the ACA's "family glitch fix" in the 4th quarter, as people enroll in individual and family plans (IFPs) on state exchanges. The fix was introduced in the middle of last year's enrollment season, but it was confusing, many people were unaware of it, and it was likely underutilized. Now that it's more familiar, I hope to see more people use it when enrolling in 2024 plans.
I also foresee a lot of panic about the new Gag Clause Prohibition Compliance Attestation (GCPCA) form, which is due for the first time on December 31, 2023, and each year thereafter. The Consolidated Appropriations Act (CAA) of 2021 immediately prohibited plans and providers from entering into "gag clauses" that prohibited the release of provider rates and other unidentified claims data, so that the transparency provisions of the CAA could function. The law also required an attestation of compliance, but regulators did not release the form until earlier this year. In most cases, compliance for fully-insured plans will be handled by the insurance issuer. For self-funded plans, employers will need to work with their plans' ASOs and TPAs to ensure compliance with this new requirement in 2023 and beyond.
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