Implementation Dates for Group Health Plan Transparency Rules

This document is a guide that outlines the implementation dates for new transparency requirements applicable to group health plans as mandated by the Affordable Care Act (ACA) and the Consolidated Appropriations Act, 2021 (CAA). It details the confusion arising from overlapping and inconsistent transparency rules, which have created challenges for plan sponsors and health care providers. The guide discusses the final rules implementing ACA transparency-in-coverage cost-sharing disclosure provisions and the earlier effective dates established by the CAA. It also presents joint agency FAQs issued by the Departments of Labor, Health and Human Services, and Treasury to assist employers in navigating these complexities. Furthermore, the guide lists specific provisions with current or upcoming effective dates, such as the prohibition on gag clauses and surprise billing rules. It emphasizes the need for plan sponsors to collaborate with third-party administrators to ensure compliance with these requirements and prepare for additional guidance.