The Compliance Download, September Vol. 1

No Surprises Act Update: Are You Ready for the New IDR Requirements?

New guidance has clarified when key No Surprises Act Independent Dispute Resolution (IDR) requirements take effect. While some rules are already in place, others will be phased in as the federal IDR Gateway becomes operational. Understanding these timelines now can help you avoid compliance gaps and ensure your health plan and vendors are prepared.  

What should you do? 

• Discuss IDR payment processes with your TPAs and vendors, ensuring that legacy procedures are appropriately closed.  

• Verify your TPA and vendors are ready for updated negotiation, dispute, and eligibility review procedures. 

Bottom line: The IDR process is becoming more structured, with new deadlines and operational requirements. Vendors will be responsible for most of the heavy lifting, though plan sponsors’ total costs are impacted by the procedure changes. You must be informed of how the process occurs, including impact on plan spend. 

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Are Your Disclosures Up to Date? Wellness Program Compliance Update

Federal agencies recently issued guidance clarifying compliance requirements for health contingent wellness programs, including tobacco surcharge programs. The guidance provides temporary enforcement relief by allowing plans to apply rewards prospectively after a participant satisfies a reasonable alternative standard, rather than requiring the reward to be applied retroactively to the start of the plan year. However, all other HIPAA wellness program requirements remain in effect.  

What should you do? 

• Review wellness program communications to ensure reasonable alternative standard notices are included whenever program terms are described.  

• Confirm participants are informed how to request an alternative standard and that physician recommendations will be accommodated.  

• Verify wellness vendors, carriers, and TPAs are administering rewards and surcharges in accordance with current requirements.  

Bottom line: While the new guidance provides flexibility around reward timing, wellness program disclosure and compliance obligations remain a key area of regulatory focus. A quick review now can help reduce compliance risk and participant complaints.  

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