Action Required | Important Update on Machine-Readable Files

June 1, 2022

The federal Transparency in Coverage rules require health plan sponsors to provide pricing disclosures via separate sets of machine-readable files (MRFs) posted on a public website (enforcement begins July 1, 2022). The intent of this aspect of the federal transparency rules is to make public the financial arrangements in place between health plans and providers. These MRFs are not for participant use, but rather the files are designed to be read by a computer system and are intended to be available for researchers and policy makers to have access to health plan costs nationally on an aggregate basis. The health plans (i.e., carriers and third-party administrators) have the information needed to compile the data and create these MRFs, and we have confirmed they will produce and provide access to these files and they will update the MRFs at least monthly.

Effective July 1, 2022, the MRFs must include:

• For In-Network providers, the data file must include the negotiated rates for covered items and services between the plan and in-network providers.

• For Out-of-Network claims,  the data file must include historical allowed amounts and billed charges for covered items and services provided by out-of-network providers.

While the health plans need to provide access to the data files, the rules appear to make it a plan sponsor’s responsibility to publicly post access to the MRFs.

• For plan sponsors that have “fully-insured” health plans, it will be the carrier’s responsibility to post links to the MRFs on their web site. Fully-insured groups do not need to act at this time and can rely on the insurance carrier to satisfy the requirement.

• For plan sponsors that have “self-insured” health plans, it will be the plan sponsors’ responsibility to post access to the MRFs on a publicly available web site that does not require log in or restricted access. Pending further guidance, self-insured sponsors must determine the most appropriate means to meet this requirement.

For self-insured plan sponsors, Conner Strong & Buckelew has created two solutions to assist in complying with these new rules:

• For sponsors with a BenePortal site created by Conner Strong & Buckelew, we will create a new section devoted to the MRF issue and include the appropriate links. There is nothing for groups to do that have a BenePortal site.

• For sponsors who do not have a BenePortal site created by Conner Strong & Buckelew, we will create a simple web-site landing page that will provide links to the health plan MRF files. The sponsor can then host the link to this site on a publicly available web site. Most will simply add the link to their organization’s “information” section on their corporate public facing web site labeled, “Federal Healthcare Transparency Requirements.”

Since the rules and requirements are new, we expect there may be more federal guidance in the future. We will keep you abreast of continued developments. Your Conner Strong & Buckelew account team will work with you to discuss your organization’s specific set-up requirements.

Please contact your Conner Strong & Buckelew account representative toll-free at 1-877-861-3220 with any questions. For a complete list of Legislative Updates issued by Conner Strong & Buckelew, visit our online Resource Center.