First and foremost is the passage and implementation of both the Transparency in Coverage rule and the No Surprises Act. The goal of the new transparency legislation is to: The Transparency in Coverage rule will be • Empower, inform, and incentivize action from implemented in three phases. consumers that enable comparison shopping. The 昀椀rst phase is the public posting of pricing • Shine light on hidden business arrangements data, known as the “machine-readable 昀椀les” or between payers and providers to stabilize and “MRFs.” The second phase is progressing to a more reduce the price of health care services overall. personalized transparency experience for plan • Expose real-time pricing information and out-of- members in 2023 and 2024. The 昀椀nal phase is a pocket liability so the U.S. can establish a market- deployment of a consumer cost estimate tool. This driven health care system. will require plan sponsors of self-insured plans and fully insured group health plans to disclose • Create a foundation of pricing data standards extensive price and cost-sharing information across the board. through public disclosures and plan participant disclosures.1 1 Transparency in coverage: What are the key phases and scope? Phase 2: Phase 3: Phase 1: Document Personalize Expand January 1, 2022 January 1, 2023 January 1, 2024 (enforcement delayed until O昀昀er an internet-based, Expand the internet- July 1, 2022) consumer cost-estimate based consumer cost- Created public machine-readable tool that provides estimate tool to include 昀椀les (MRFs) that display in-network personalized, out-of- cost estimates for all rates, out-of-network allowed pocket cost estimates and covered items, services, amounts, and prescription other price-related data and prescription drugs. drug pricing.1 for 500 pre-determined • Plan years beginning from 1/1/22 items and services. to 6/30/22 began disclosing the 昀椀rst MRF (medical) by July 1, 2022. • Plan years beginning on or after Quality data is not part of the 7/1/22 began disclosing by the end of the month in which the mandatory disclosures in the rules. year begins. 2023 Benefits Trends: The evolving workplace 78
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