2022 is just around the corner. That means you’re planning for your health, fringe and leave benefits for the new year.
The pandemic has made this challenging. And the Biden administration’s policy changes are making it even more confusing. Why?
There are a number of proposed reforms that would affect health and leave programs. And the administration isn’t done. It continues to plow ahead with its health policy agenda.
Regulators are trying to provide guidance on changes that have already taken place. One of them is the new transparency in coverage reg set to take effect Jan. 1, 2022. But they’re having a tough time keeping up.
So where does that leave employers?
Scrambling to show good-faith compliance, even though they don’t have all the answers yet.
Here are Mercer’s Top 5 compliance priorities for planning 2022 health, leave and fringe benefits:
1. COVID-19 issues
The pandemic and the issues it’s brought with it aren’t going anywhere soon. So for now review the continuing coverage mandates and various COVID-19 relief programs. Another priority is communicating with plan participants. They need to know about pandemic-related benefits and group health plan deadlines.
Employers can continue benefit enhancements beyond coverage period or go back to prepandemic terms. Just document and communicate what you’re doing with plan participants.
2. Workplace safety
Things to consider: Will you encourage or mandate vaccines? Will you have all employees return to the worksite, stay remote or a hybrid of both?
It’s also important to monitor local conditions, and have a contingency plan in place as pandemic conditions change. Your employees need to know your operating plan for 2022 prioritizes their safety, health, diversity and inclusion.
Along with the final transparency in coverage rules for group health plans, you also need to prepare for new transparency requirements under the 2021 Consolidated Appropriations Act (CCA) effective for plans beginning on or after Jan. 1, 2022. While CCA’s transparency requirement guidance is coming, it’s on you – plan sponsors – to make good-faith efforts to comply until they’re available. It’s also important to review price disclosures and comply with the final hospital transparency regulation.
4. Surprise billing
On Jan. 1, 2022 the No Surprises Act takes effect. It provides comprehensive patient protections against surprise medical bills. While Part I of the interim final rule has been released, be on the look out for additional regs later this year and in 2022. When they’re released, review the new law and rules, confer with third-party administrators and carriers, and prepare to comply. Deadlines will be tight. Make sure to include new disclosures in plan documents and EOBs.
5. Gender, family planning benefits
When it comes to diversity, equity and inclusion (DEI) goals, it’s no longer enough to be compliant with the law. While improving your family planning benefits efforts is important, you also have to consider federal tax rules, ACA mandates and state laws when designing plans that include fertility, adoption and surrogacy benefits.
Click here for even more priorities.