On December 27, 2020 the Consolidated Appropriations Act(CAA) COVID-19 Relief bill was signed into law. This bill included many healthcare provisions including the Transparency in Coverage requirement. This requires Self-Funded/Level Funded health plans or issuers to publicly provide certain health care price information via Machine-Readable Files (MRF) on their own public websites effective July 1, 2022. The MRF will include such information as negotiated rates with in-network providers and allowed amounts for out-of-network providers. Reporting on Pharmacy Benefits and Costs will be also be required but is currently pending additional rule making. We are anticipating the compliance date for the Pharmacy Benefits requirement to be December 27, 2022. We at will update your organization as any additional information becomes available.
What are the requirements?
Employers sponsoring a self-funded/level-funded medical plan are required to post links/source date to those machine-readable files that contain the pricing information on a publicly available website to any person free of change and without conditions, such as establishing a user account, password, any other type of credentials, or submission of any personally identifiable information to access the file. This link must be on the front page of the company’s publicly facing website. The font size and color must be the consistent with rest of the webpage. The link should be on easily identified on the page and must be labeled “Transparency in Coverage”.
The source link for the Transparency in Coverage is: https://www.bluecrossnc.com/about-us/policies-and-best-practices/transparency-coverage-mrf# This is the source information that will connect back to the external site where the MRF is hosted and allow the file to be downloaded. Please be aware that this link many not be active until July 1, 2022.
Enforcement on this begins on July 1, 2022 with potential files of up to $ 100.00 per day for each violation and for each individual affected by the violation.