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Consolidated Appropriations Act – New ID Card Requirements

Aug. 26, 2021 – Consolidated Appropriations Act (CAA) Update

One of the provisions of the Consolidated Appropriations Act (CAA) requires that health insurance companies and group health plans (groups) include new information on member ID cards. We’re working now to make good-faith efforts to implement the requirements as we understand them from the law. We expect that Federal agencies will issue regulations or other guidance after Jan. 1, 2022, so we’ll be sure to keep you updated as we learn more.

This article provides general information about the CAA’s ID card provision and our plan for implementation. It is not legal advice. If you have specific questions about compliance with the ID card requirements or other CAA provisions, please contact your legal counsel.

New ID Card Requirements

For plan and policy years beginning on or after Jan. 1, 2022, the CAA requires physical and electronic ID cards to include, in clear writing, any deductibles and out-of-pocket (OOP) maximums, including in-network and out-of-network amounts. ID cards must also include a phone number and website where members can get more information, including details about network providers.

This provision applies to commercial non-grandfathered and grandfathered groups and individual policies. It doesn’t apply to excepted benefits like stand-alone dental and vision coverage or Medicare supplement plans. It also doesn’t apply to government programs such as Medicare Advantage plans or Medicaid coverage.

What’s BlueCross Doing?

The good news is that we already have a phone number and website on our current ID cards. We’re including deductible and OOP fields for coverage we administer on ID cards for plan and policy years beginning on or after Jan. 1, 2022.

Deductible and OOP amounts will be clearly labeled, and we’ve tested the changes with members to make sure the new information is easy to read and understand.

What Will the New Card Look Like?

Below are two sample cards for typical plans – a PPO and a high-deductible health plan (HDHP) with in-network and out-of-network benefits. Actual cards may differ based on plan specifics.

Will BlueCross Issue New ID Cards?

For new groups and individual policyholders with 2022 effective dates, all subscribers will get physical ID cards that include deductible and OOP fields for coverage we administer. Digital cards will also include the new details. Subscribers can access their digital cards on our BCBSTN mobile app and download a temporary card from their secure member account on

For existing groups, we’ll maintain our current process and issue a new physical ID card only when a change in status triggers a new card to be issued such as a change in network or copays, or a product like dental or vision is added or removed. However, subscribers can request cards through the BCBSTN mobile app, on, or by calling the number on the back of their ID card. If a physical card is issued after a group confirms their 2022 renewal, it will include the deductible and OOP fields for coverage we administer. All digital cards will be updated with the new details when a group renews.

As announced in February, CVS Health will be our new pharmacy benefit manager (PBM) on Jan. 1, 2022, so groups with our pharmacy coverage will get new ID cards in December. Here’s how this mass reissue will work with the CAA ID card requirements:

  • Groups with pharmacy coverage and Jan. 1 renewal dates: Cards issued in December will include updated pharmacy information along with additional deductible and OOP information. Cards will only be issued once a group has confirmed their renewal.
  • Groups with pharmacy coverage and later renewal dates: Cards issued in December will include updated pharmacy information only.
  • Groups that do not have pharmacy coverage with us: Cards will not be re-issued in December.

What About Groups that use Multiple Service Providers?

BlueCross will add deductible and OOP information to cards for coverage we insure or administer. Self-funded groups that provide coverage administered by another service provider, such as pharmacy or behavioral health, will need to contact the other entity regarding ID card requirements that may apply.

We’re Here to Help

Please contact your BlueCross Sales or Account Executive with questions.