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What do you need to know about the newly issued Part 49 FAQs

On August 20, 2021, the Departments of Labor, Health and Human Services, and Treasury (the Departments) issued FAQs about Affordable Care Act and Consolidated Appropriations Act, 2021 Implementation Part 49 (the Part 49 FAQs). The Part 49 FAQs are intended to provide clarification and relief with regard to transparency requirements under Patient Protection and Affordable Care Act (ACA) and the Consolidated Appropriations Act, 2021 (the CAA).


Due to some overlaps in the requirements and a short timeline for application of certain provisions, the Departments issued the Part 49 FAQs to provide for some relief in and clarification for compliance.


Gallagher’s Compliance Consulting practice shares highlights from the Part 49 FAQs, including guidance on:


  • Transparency in Coverage Machine-Readable Files
  • Price Comparison Tools
  • Transparency in Plan or Insurance Identification Cards
  • Good Faith Estimates
  • Prohibition on Gag Clauses on Price and Quality Data
  • And more!

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