The federal Transparency in Coverage rules require group health plans to display certain health care price information via machine-readable files (“MRFs”) on a publicly available website. These MRFs must include negotiated rates with in-network providers and allowed amounts for out-of-network providers. These files must be accessible at no charge on a public website that anyone can access without any restrictions, and they must be updated monthly. Enforcement began as of July 1, 2022.
For employers sponsoring fully insured health plan options, it will be the responsibility of the insurance carrier to post the files on their web site. However, pending further guidance, for employers sponsoring self-insured health plan options, it will be the employer’s responsibility to satisfy this MRF disclosure obligation. The purpose of making these MRFs available is so researchers, regulators, and application developers may access and analyze the data more easily. MRFs are designed to be read by a computer system and are not intended for employees and plan members.
The posting of MRFs is part of a broad transparency approach promoted by the federal government so that consumers, employers, and plan sponsors will have access to the cost of medical care in advance of getting a procedure. The MRF requirement is just one aspect of the expansive federal transparency rules. Last year hospitals were required to post the cost of certain services to their web site and next year, insurers and third-party administrators will be required to give plan members an advanced explanation of benefit describing the cost of care before one receives it.
This link provides a CSB Compliance Overview and Q&A designed to give employers and plan sponsors the information they need to determine the most appropriate course of action to comply with the MRF posting rules.
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.
