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ARTICLE · 23 JUNE 2022

Transparency In Coverage Deadline Looms – Are You Ready?

Mayer Brown
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Group health plans have historically been able to satisfy many disclosure obligations through hard copy distributions, intranet postings and e-mails.

United StatesEmployment and HR
Keane Garcelon
Keane Garcelon
Stephanie B. Vasconcellos
Stephanie B. Vasconcellos
Debra Hoffman
Debra Hoffman
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The Affordable Care Act contains broad provisions requiring health insurers and group health plans to make substantial amounts of information available to the public to facilitate transparency in health care pricing, and several recent Executive Orders have also focused on the availability of health pricing information. In 2020, under the authority of the Affordable Care Act, the Departments of Health and Human Services, Labor, and the Treasury issued transparency in coverage regulations (often referred to as the "TiC Rules"), which require most health plans and health insurance issuers in the group and individual markets ("Plans and Issuers") to publicly disclose health plan pricing and cost sharing information. The first deadline under the TiC Rules was originally set for January 1, 2022, but was delayed to July 1, 2022 in part due to the enactment of the Consolidated Appropriation Act (which contained additional, and somewhat overlapping, transparency in

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