Transparency in Coverage Disclosures
In compliance with the federal Transparency in Coverage (TiC) regulations and the Consolidated Appropriations Act (CAA) of 2021, employer group health plans are required to provide public access to cost data for covered medical and pharmacy services.
What’s Required
Effective July 1, 2022, employer group health plans must:
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Publish machine-readable files (MRFs) with in-network provider rates for covered items and services.
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Publish machine-readable files (MRFs) with out-of-network allowed amounts and billed charges for covered items and services.
How This Applies to Employers
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Fully Insured Plans
Employers with fully insured plans may meet these requirements by entering into a written agreement with their insurance carrier to publish the files.-
Aetna, Anthem, and Oxford/UnitedHealthcare have provided these agreements, so no further employer action is required.
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Cigna, ConnectiCare, Oscar + Cigna, and Harvard Pilgrim have not released such agreements. Employers using these carriers must post a link on their public-facing website to the carrier’s machine-readable files.
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Level-Funded or Self-Funded Plans
Employers offering these plans must:-
Obtain a written agreement from their carrier to publish the required files, and
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Provide a link on their own public-facing website to where the carrier publishes the files.
Even with a written agreement, plan sponsors may remain responsible if disclosures are not properly made.
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