No. The Supreme Court’s decision only applies to a narrow subsection of payers – specifically, to ERISA plans.  The decision does not affect the legal obligation under the Colorado statute and implementing regulations for non-ERISA self-funded employer sponsored health plans that have 100 or more covered lives or any other entities that meet the definition of payer under 10 C.C.R. § 2505-5(1.200) to submit claims data to the CO APCD.

in Self-InsuredSubmissions