On August 20, 2021, the Departments of Health and Human Services (“HHS”), Labor (“DOL”), and the Treasury (collectively called “the Departments”) jointly issued an FAQ which implements parts of the Consolidated Appropriations Act (“CAA”) that was passed at the end of 2020 and the Transparency in Coverage (“TiC”) final regulations that were issued in November of 2020. The requirements under the CAA apply to all group health plans, including grandfathered plans.

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Some Transparency in Coverage and CAA Deadlines Delayed – 090221R