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Consolidated Appropriations Act

Helping employers meet compliance requirements 

Resulting from the Consolidated Appropriations Act (CAA) that Congress passed, employers have a legal responsibility to be good stewards of their health insurance spending. Security Health Plan, as a health coverage partner, is taking steps to help employers become more aware of their group prescription drug and health care spending practices.

CAA mandates and reporting requirements are designed to help employers focus on and demonstrate financial responsibility. Some CAA focus areas include pharmacy reporting, mental health parity compliance, consumer price transparency, balance-billing practices, and contract and pricing transparency between vendors, brokers, carriers, etc.

Below are the steps we’re taking to help make compliance easier.

Fully-insured employer groups

Gap Rule (AKA Gag Clause)
Security Health Plan will attest for itself and on behalf of all fully-insured employers that we don’t include any language that restricts access to specific cost and quality information in any of our direct-contract networks.

Pharmacy benefit and drug cost reporting
For fully-insured employers who use Optum, our pharmacy benefit manager (PBM), Security Health Plan will complete all reporting requirements. Reporting requirements include the following, which we report to Health and Human Services (HHS), the Department of Labor (DOL) and the Department of Transportation (DOT):

No Surprises Act – protections from balance billing
When a member receives emergency care or treatment by an out-of-network provider at an in-network hospital or ambulatory surgical center, protections against balance billing exist. In these cases, a member shouldn't be charged more than their plan’s copayments, coinsurance and/or deductible. Please see https://www.securityhealth.org/no-surprises-act  for detailed information.

Compensation disclosures
We share commission information with our external sales brokers on a monthly basis so brokers can disclose that information with their employer clients. 

Transparency in coverage rules (consumer transparency tool and machine-readable files)
Regarding consumer transparency, we have provided an online price transparency tool with all required services. To access this information, your employees must be logged in to   My Security Health Plan . Machine readable files are published monthly to this web link: JSON–Machine Readable Data |Security Health Plan.

Deductibles and copays on ID cards
We now include this information on member ID cards.

Mental Health Parity and Addiction Equity Act (MHPAEA)
To ensure compliance with MHPAEA, Security Health Plan conducts annual specialized testing on our plan designs offered in the fully-insured product line to ensure our mental health/substance use disorder benefit limitations are not less favorable than those limitations on medical/surgical benefits. We review the results and/or recommendations of the testing and make modifications, if necessary. 

Self-insured and level-funded employer groups

Gap Rule (AKA Gag Clause)
Self-insured employers, including level-funded, are required to submit the attestation themselves. Security Administrative Services will provide a formal letter to these employers stating our contracts comply with the rule. The Centers for Medicare and Medicaid Services (CMS) has multiple resources on this attestation, which can be found at https://www.cms.gov/marketplace/about/oversight/other-insurance-protections/gag-clause-prohibition-compliance-attestation.

Pharmacy benefit and drug cost reporting
For self-insured employers who use our pharmacy benefit manager (PBM), Optum, Security Health Plan along with Optum, will complete all reporting requirements. Self-insured employers who use a PBM other than Optum must have the other PBM report on their behalf. Reporting requirements include the following, which we report to Health and Human Services (HHS), the Department of Labor (DOL) and the Department of Transportation (DOT):

No Surprises Act – protections from balance billing
When a member receives emergency care or treatment by an out-of-network provider at an in-network hospital or ambulatory surgical center, protections against balance billing exist. In these cases, a member shouldn't be charged more than their plan’s copayments, coinsurance and/or deductible. Please see https://www.securityhealth.org/no-surprises-act    for detailed information.

Compensation disclosures
Security Administrative Services does not compensate brokers for business. However, it does disclose any and all payment agreements with third-party vendors that support operations and plan administration.

Transparency in coverage rules (consumer transparency tool and machine-readable files)
Regarding consumer transparency, we have provided an online price transparency tool with all required services. To access this information, your employees must be logged in to My Security Health Plan . Machine readable files are published monthly to this web link: JSON - Machine Readable Data |Security Health Plan.

Deductibles and copays on ID cards
We now include this information on member ID cards.

Mental Health Parity and Addiction Equity Act (MHPAEA)
Self-insured employers must conduct their own MHPAEA analysis and are encouraged to discuss questions with their legal counsel early on in the process. Upon request, Security Administrative Services will provide self-insured employers with any necessary plan documentation required to conduct the testing and will work with the plan sponsor on adopting any recommended changes to the plan design resulting from the testing.