Consolidated Appropriations Act: Medical ID Cards Will Change in 2022

Late last year in 2020, Congress passed a stimulus package entitled Consolidated Appropriations Act (CAA), 2021 (we wrote about the benefit-related provisions here).

The 5,600 page bill included a section on health plan transparency. Some of those specific provisions are set to go into effect starting January 1, 2022.

A health plan transparency measure with regards to medical ID cards has been receiving attention as health plan insurers start to communicate how they will comply starting with plans renewing on or after 1/1/2022.

What is it? CAA, 2021 health plan transparency rules include a requirement that medical ID cards must reflect the following:

  • Plan deductibles: in and out-of-network amounts
  • Maximum limits on out-of-pocket costs including network and out-of-network limits, as applicable
  • Phone number and web address for a member to get assistance including help to find a network provider

Who must comply? For fully insured plans, the carrier/insurer will make the new ID cards available. For self-insured plans, the employer/group health plan should work with their TPA to ensure compliance.

When do ID cards have to be issued with the new requirements? In general, insurers and group health plans must make the new ID cards available to individuals at renewal, on or after 1/1/2022.

The law does not require new ID cards to be mailed. Printed cards will be sent in accordance with carrier guidelines.

What can employers do now? It’s likely that fully insured plans will receive information from the group health plan carrier soon that describes its protocols regarding the new medical ID cards. The employer can work with their carrier to understand how members will be affected and when.

Self-insured group health plan administrators should work with their TPA to ensure compliance of these new Medical ID card requirements.

While every effort has been taken in compiling this information to ensure that its contents are totally accurate, neither the publisher nor the author can accept liability for any inaccuracies or changed circumstances of any information herein or for the consequences of any reliance placed upon it. This publication is distributed on the understanding that the publisher is not engaged in rendering legal, accounting or other professional advice or services. Readers should always seek professional advice before entering into any commitments.


About Michelle Cammayo

Michelle Cammayo has more than 13 years of Employee Benefits experience specializing in all lines of health and welfare benefits. Today, Michelle works closely with clients and partners to provide guidance in areas of the law including ERISA, HIPAA, COBRA, FMLA and PPACA. She also oversees the Compliance Department at Bolton & Company to ensure we are helping our clients manage and eliminate risk with regards to employee benefit compliance.

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