Nov 23, 2021

2022 Mandates and Policy Updates

ID Card Requirements 
The Consolidated Appropriations Act (CAA) requires that insurance identification cards (ID cards) indicate the plan’s in-network and out-of-network deductibles, out-of-pocket maximums, and a phone number and website address where members may seek consumer assistance information.

  • Blue Cross & Blue Shield of Rhode Island (BCBSRI) is currently working to update both the physical and electronic ID cards to include the required information.
  • BCBSRI will issue updated ID cards to all members upon renewal, beginning with January 2022 renewals.

Surprise Billing
BCBSRI is implementing the CAA surprise billing requirements at no additional cost, including making necessary changes to subscriber agreements and benefit books, processing claims as required by the statute, negotiating with providers, and participating in the dispute resolution process for fully insured plans and those self-funded plans that choose to calculate the payments under these requirements based on all of BCBSRI’s self-funded claims experience. 

If a self-funded plan chooses, instead, to calculate those required payment amounts based on just its own claims experience, additional charges may apply. Unless the self-funded client directs BCBSRI otherwise, BCBSRI will assume the plan intends BCBSRI to use all of BCBSRI’s self-funded claims experience to calculate payment amounts.

Doula Services 
BCBSRI will cover services rendered by certified doulas for fully insured and self-funded clients, effective January 1, 2022, unless the self-funded client directs us otherwise. Doula services will be covered as part of a broader maternity Care Management program at no cost share to the member (including members with HSA-qualified products). 

Pharmacy Accumulator 
Beginning January 1, 2022, a pharmacy accumulator adjustment program will be implemented for all HSA-qualified high-deductible health plans (HDHPs), for both fully insured and self-funded clients, upon renewal, unless the self-funded client directs BCBSRI otherwise. This program is being initiated in alignment with IRS requirements that HDHPs may only take into account the amount paid by the member when determining whether an individual has satisfied their deductible.

Colorectal Screening Update
Effective January 1, 2022, the recommended age to begin receiving preventive colorectal cancer screenings (colonoscopies) at no cost share will change from 50 to 45 years of age in the BCBSRI medical policy, based on updated U.S. Preventive Services Taskforce recommendations.

Dental Portfolio
Beginning January 1, 2022 upon renewal, BCBSRI is expanding dental coverage for composite (white) fillings on both front and back teeth in the Large Group market. This change brings our filling coverage to market parity and will have a minimal impact on rates.

  • New dental product IDs will be required.
  • All dental clients with a product ID-based 834 file will need to retest the file as part of their 2022 renewal.
  • Once the 2022 client decision has been communicated, a Client Implementation Manager (CIM) will contact each client’s enrollment vendor to coordinate renewal testing at the appropriate time.

Insulin Drug Copay Cap
Starting January 1, 2022 for fully insured clients and upon renewal for self-funded clients, members will not pay more than a $40 copay for prescription insulin drugs per 30-day supply, unless the self-funded client directs BCBSRI otherwise.

  • The $40 limit applies to all Commercial products, including HSA-compatible products, regardless of whether the client has the PDL.

Specialty Pharmacy / Mail Order Changes
Effective January 1, 2022, the mail order pharmacy services will be provided by Express Scripts (ESI) Home Delivery, and Accredo, an ESI subsidiary, will be designated as the specialty pharmacy for BCBSRI.

Cost share waiver for COVID-19 treatment
In April 2020, BCBSRI temporarily waived member cost share for treatments related to COVID-19, including emergency services, inpatient services, and provider office visits when received in-network.

  • As of December 31, 2021, unless the self-funded client directs us otherwise, the cost share waiver will expire and coverage for treatment related to COVID-19 will be covered under members’ standard plan benefits.
  • A further extension of the cost share waiver may be provided if the current state of emergency extends into 2022.
  • Please note that members will continue not to need preauthorization or a referral for these COVID-related services.

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