Requirement to Post Machine-readable Files Begins July 1, 2022

     The Transparency in Coverage Final Rules (TiC Final Rules) require group health plans and health insurance issuers to disclose on a public website detailed pricing information in three separate machine-readable files (MRFs). Specifically, the following information must be disclosed:

  • First file: In-network provider negotiated rates for covered items and services (the “In-network Rate File”);
  • Second file: Historical payments to and billed charges from out-of-network providers (the “Allowed Amount File”); and
  • Third file: In-network negotiated rates and historical net prices for covered prescription drugs (the “Prescription Drug File”)—this particular MRF requirement is delayed until further notice.The files must be publicly available and accessible free of charge without any restrictions.

Action Steps

     Most employers will rely on their insurance carriers and third-party administrators (TPAs) to provide the MRFs. The TiC Final Rules allow fully-insured employers to shift legal responsibility for the MRFs to their carriers if this arrangement is described in a written agreement. Self-insured employers can use their TPAs (or other service providers) for the MRFs if this is set forth in a written agreement. Still, these employers remain legally liable for compliance under the TiC Final Rules.

     The TiC Final Rules suggest that self-insured employers may be required to post a link on their websites to where the MRFs are publicly available, but this is not clearly addressed in the Final Rules. Additional guidance from federal agencies on this topic would be helpful.

Employers should confirm that written agreements addressing MRFs are in place with their carriers and TPAs and that these files will be available by the applicable deadline.

Enforcement Dates

Jan. 1, 2022

The MRF requirements are applicable for plan years beginning on or after Jan. 1, 2022.

July 1, 2022

Federal agencies deferred enforcement of the first and second MRFs related to disclosing in-network and out-of-network data until July 1, 2022. (Enforcement of the third MRF relating to prescription drugs is delayed until further notice.)

Plan Years Beginning After July 1

For 2022 plan years beginning after July 1, 2022, MRFs must be posted in the month in which the plan year begins (for example, Sept. 1, 2022, for a plan year that is from Sept. 1 to Aug. 31).

Covered Plans

The rules apply to group health plans and health insurance issuers in the individual and group markets.

The rules are not applicable to grandfathered plans, excepted benefits and account-based plans, such as HRAs, FSAs and HSAs.

Download the full PDF here – Requirement to Post Machine-readable Files Begins July 1, 2022

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