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New FAQs Address Transparency in Coverage Disclosures on Health Plan Websites

The Transparency in Coverage Final Rules require an employer-sponsored group health plan to post three machine-readable files on a public website. Two of these files, the network rate and non-network allowed amount files, were required to be posted by July 1, 2022. Recently issued FAQs provide that a plan may satisfy this requirement by entering into a written agreement under which a service provider (such as a TPA) posts the machine-readable files on its public website on behalf of the plan. However, in the case of the non-network aggregated allowed amount files (i.e., the third machine-readable file that must be published), the plan must post a link to the file hosted by the service provider on the plan’s own website, if the plan maintains a public website. It is not clear from this FAQ whether the TPA must post this information on its public website where information is normally made… Continue Reading

August 2022
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