Transparency In Coverage Requirements – Compliance Deadline Approaching

Summary: For Health Plans, Machine-Readable Files, containing in-network provider charges and out-of-network allowed amounts and billed charges, must be posted on a public website by July 1, 2022.

Background

The public disclosure requirement is required under final "transparency in coverage" rules ("TiC Rules") published in November 2020 by the Internal Revenue Service, Department of Labor, and Department of Health and Human Services ("Agencies"). The TiC Rules are intended to implement cost transparency requirements imposed by the Affordable Care Act. The TiC Final Rules apply to non-grandfathered group health plans and insurers offering non-grandfathered coverage and require cost-sharing disclosures be made available by most health plans and insurers. Shortly after the TiC Final Rules were issued, the Internal Revenue Service, the Department of Labor, and the Department of Health and Human Services (the "Departments") jointly issued regulations clarifying