July 6, 2016

August Deadline for ASO Groups to Advise of ERISA Status

Update: Groups must advise their account management if they are non-ERISA and subject to the state APCD reporting requirements by Aug. 1.

Background: As we reported previously, on March 2, the U.S. Supreme Court issued a decision in Gobeille v. Liberty Mutual, the case involving Vermont's all-payer claims database ("APCD") law and its requirements regarding self-funded employer plans.

The Court ruled in favor of Liberty Mutual, holding that ERISA pre-empts Vermont's requirements that ERISA plans provide data to the Vermont APCD. As a result of this ruling, Blue Cross and Blue Shield of Texas (BCBSTX) no longer submits data on behalf of self-funded ERISA groups in Maine, Minnesota, Vermont or Colorado.

Self-funded plans that are not subject to ERISA, such as church plans or government plans, may continue to be subject to these data reporting requirements. The self-funded plan has sole responsibility to determine whether it is subject to ERISA and to the state APCD reporting requirements.

Because the plan must determine ERISA status, BCBSTX will not submit data for any ASO groups who do not inform account management that they are subject to state APCD reporting requirements and require data submission.

This communication is intended for informational purposes only. It is not intended to provide, does not constitute, and cannot be relied upon as legal, tax or compliance advice. The information contained in this communication is subject to change based on future regulation and guidance.

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