Compliance Summary Table

Type of Requirement	Requirement	Brief Description	What Yuzu Provides
Form Completion	Forms 1094-C / 1095-C Filing	ACA employer reporting confirming MEC was offered. Required for ALEs (50+ FTEs). Due Jan 31 / Mar 31.	We don't file on behalf of plans, but we do prepare the forms. See guide.
Form Completion	RxDC Reporting	Annual Rx drug and health care spending data report to CMS. Due June 1. Carrier/TPA typically submits on plan's behalf.	We file for groups who input Employee Premium Contributions. See guide.
Form Completion	Medicare Part D CMS Disclosure	Annual online disclosure to CMS confirming plan drug coverage is creditable. Due within 60 days of plan year start.	We do not file this form, but we do include whether a member has creditable coverage on their Proof of Coverage letter. See guide.
Health Administration	External Review Process	Independent external review required for adverse benefit determinations involving medical judgment or rescission.	Our claims team runs our internal appeals process. Guidelines around external review are outlined in each plan’s Summary Plan Description.
Notice to EE	Summary of Material Modifications (SMM)	Written notice to participants when plan changes materially. Due 60 days after material benefit reduction.	We have SMM templates on file and can assist health plans in their creation, but we do not independently issue the SMMs to groups (it is the plan’s obligation).
Notice to EE	Medicare Part D Creditable Coverage Notice	Annual notice by Oct 15 to Medicare-eligible participants: is plan drug coverage at least as good as Medicare Part D?	The member's Proof of Coverage letter lives in their portal year-round. It contains information about whether or not they have creditable coverage. See guide.
Notice to EE	Women's Health & Cancer Rights Notice	Annual notice: plans covering mastectomy must also cover reconstruction, prostheses, and related treatment.	We follow these guidelines but do not provide this notice.
Notice to EE	Surprise Billing Patient Protections Notice	Plans with a public health plan website must post notice of participant protections against surprise billing.	This is included in our Summary Plan Description.
Notice to EE	HIPAA Notice of Privacy Practices	Informs participants how PHI is used and disclosed. Required for self-funded plans.	This is included in our Summary Plan Description.
Plan Administration	Cost Estimator Tool	Online cost-sharing estimator for covered items/services available to participants through carrier or TPA member portal.	This is in our product pipeline, but not yet live on our portal.
Plan Administration	Provider Directory / Transparency Tool	Accurate, up-to-date provider directory. Online directories updated within 2 business days of network changes.	We have a Provider Search for plans with Direct Contracts which we update regularly. Yuzu is typically responsible for reflecting the most current NPI / TIN mappings we receive from the health system or network owner. We are not often the source of truth for provider NPI / TINs and we don't handle credentialing. This is somewhat flexible and we are open to discussing roles & responsibilities further.
Plan Administration	No Surprises Act – Good Faith Cost Estimates	Upon request, plan must provide good faith cost estimates for scheduled OON services within 3 business days.	It is the provider's obligation to provide a GFE, but is sometimes handled by care navigation services of the plan if the plan chooses to use a separate navigation service.
Plan Administration	Rescission Prohibition	Coverage cannot be retroactively cancelled except for fraud or intentional material misrepresentation.	We follow this guideline.
Plan Administration	Plan Documents Available Upon Request	Participants can request plan documents; must be provided within 30 days. Penalty: $110/day.	We follow this guideline.
Plan Doc	Written Plan Document	Master legal document: eligibility, benefits, funding, named fiduciary, claims procedures, amendment authority, vendor references.	We follow this guideline.
Plan Doc	SPD – Summary Plan Description	ERISA-required plain-language summary of all plan terms provided to participants within 90 days of coverage.	We're able to generate the Summary Plan Description as soon as a group goes live (and often sooner if benefits and plan policy are completed and confirmed). The SPD is available in the portal as soon as it's signed.
Plan Doc	SBC – Summary of Benefits & Coverage	Standardized 4-page HHS-template benefit summary. Required at enrollment and within 7 days of participant request.	The SBC is generated and provided as soon as a group goes live.
Plan Doc	Claims & Appeals Procedures	Written procedures for claims and internal appeals meeting DOL standards. Timeframes: 15 days pre-service, 30 days post-service, 72 hrs urgent.	We follow this guideline. Appeals rights and rules are outlined in our standard Summary Plan Description under the section titled "Timing of Claim Decisions."
Plan Doc Requiement	Mental Health Parity Comparative Analysis	Written NQTL analysis for plans offering MH/SUD benefits. Must be produced within 10 business days on government request.	We produce these analyses upon request.
Plan Doc Requirement	Wellness Program Compliance	HIPAA: rewards ≤30% of coverage cost (50% tobacco). ADA: disability inquiries must be voluntary. GINA: no genetic info requests.	We follow this, and include this language in our Summary Plan Description. It is under the section titled: Genetic Information Nondiscrimination Act (“GINA”)."
Plan Doc Requirement	Minimum Essential Coverage (MEC)	Plan must qualify as MEC so employees avoid individual mandate penalty and employer avoids §4980H(a) penalty.	We follow this guideline.
Plan Doc Requirement	Affordability Standard	Employee's self-only premium share cannot exceed 9.02% of household income (2025). Employer uses W-2, rate-of-pay, or FPL safe harbor.	Employers set their employee premium contribution and are responsible for following relevant guidelines. Yuzu, in its capacity as a TPA, does not set or review employee premium contributions.
Plan Doc Requirement	Minimum Value	Plan must pay ≥60% actuarial value of covered benefits. Plans not covering inpatient or physician services automatically fail.	We follow this guideline.
Plan Doc Requirement	90-Day Waiting Period Maximum	Newly eligible employees cannot wait more than 90 calendar days before coverage begins.	We follow this guideline; our portal conducts a check for longer waiting periods.
Plan Doc Requirement	No Lifetime / Annual Dollar Limits on EHBs	Plan cannot impose dollar caps on essential health benefits over lifetime or plan year.	We follow this guideline.
Plan Doc Requirement	Out-of-Pocket Maximum Compliance	2026 limits: $10,600 self-only / $21,200 family. Plan may not exceed these for EHBs.	We follow this guideline, and our portal runs a check of these maximums.
Plan Doc Requirement	No Cost-Sharing for Preventive Services	ACA preventive services (USPSTF A/B, ACIP, HRSA) covered at $0 — no deductible, copay, or coinsurance.	We follow this guideline.
Plan Doc Requirement	Dependent Coverage to Age 26	Plans offering dependent coverage must extend to children through age 26 regardless of student or marital status.	We follow this guideline.
Plan Doc Requirement	No Pre-Existing Condition Exclusions	No waiting periods or benefit limitations based on health conditions that existed before coverage began.	We follow this guideline.
Plan Doc Requirement	No Health Status Discrimination	Eligibility and premiums cannot vary based on health status, claims history, medical condition, genetic info, or disability.	We follow this guideline.
Plan Doc Requirement	No Surprises Act – Emergency Services	Cost-sharing for out-of-network emergency services capped at in-network amounts. Plan absorbs the difference.	We follow this guideline.
Plan Doc Requirement	GINA – Genetic Information Nondiscrimination	Plan may not use genetic info (including family medical history) for eligibility, premiums, or pre-existing exclusions.	We follow this guideline.
Spend Account Admin	Machine Readable Files	Plans publicly post monthly-updated files: in-network negotiated rates, OON allowable amounts, Rx pricing.	We support this for some of our networks today at https://yuzu.health/mrfs.
Form Completion	Form 5500 + Summary Annual Report	Annual DOL/IRS return for plans with 100+ participants. SAR distributed to participants within 9 months of plan year end.	We do not file this form, but we do generate a summary of Form 5500 with all relevant information for brokers and employers to draw from. See guide.
Form Completion	Gag Clause Annual Attestation	Annual attestation to CMS by Dec 31 confirming plan has no contracts restricting access to cost/quality data.	We do not file a Gag Clause Attestation, but we do provide an attestation letter on our portal. See guide.
Asset Management	Assets in Trust / No Commingling	Plan assets must be held in a separate trust and cannot be commingled with employer operating funds.	We follow this guideline.
Form Completion	Section 111 MSP Reporting	Quarterly electronic reporting to CMS identifying Medicare-eligible covered individuals. TPA typically files but employer retains liability.	We handle all Section 111 quarterly reporting on behalf of our groups.
HIPAA	HIPAA Privacy & Security Compliance	Privacy Rule, Security Rule, BAAs with all PHI vendors, and breach notification procedures.	We follow this guideline.
Notice to EE	ACA Exchange Notice	Employees must be informed of the ACA marketplace and potential subsidy eligibility. Required within 14 days of hire.	We do not provide this notice.
Notice to EE	CHIP Notice	Annual notice to employees in CHIP premium-assistance states of potential free/low-cost public coverage.	We do not provide this notice, but we do provide information on CHIP in our Summary Plan Description. The section is titled "Additional Special Enrollment Rights."
Pay Fees’	PCORI Fee	Annual per-covered-life fee paid by self-funded plan sponsors on IRS Form 720. Due July 31.	We do not file PCORI, but we calculate the PCORI fee on behalf of our plans. See guide.
Plan Administration	HIPAA Special Enrollment Rights Notice	Informs employees of right to enroll outside open enrollment upon qualifying life events. Provided at initial enrollment.	This is included in our Summary Plan Description. The section is titled "Special and Open Enrollment."

Contents

Compliance Summary Table