Extracting Strategic Value from Delay to Price Transparency Mandates

By September 9, 2021 September 17th, 2021 Resources
Delay to Price Transparency Mandate. No Surprises Act (NSA) and Transparency in Coverage (TiC). Machine-Readable Files. Self-Service Price Estimation Tool. HealthSparq.

Staying on top of government regulations and their compliance is an ongoing reality for health plans, health systems, and care provider organizations operating in the healthcare industry.  And oftentimes when federal agencies issue a delay in enforcing new regulations many organizations breathe a sigh of relief – and then fail to take advantage of the extended time to take a more strategic approach. Recently some healthcare organizations took that sigh of relief as new guidance was issued related to the No Surprises Act (NSA) and Transparency in Coverage (TiC) health plan price transparency mandates. Among other areas, these changes impacted Machine-Readable Files and the Self-Service Price Estimation Tool. Here’s an opportunity to add more value than merely ‘checking a box.’

Enforcement of Machine-Readable Files Delayed

Enforcement of the requirement to post in-network and allowed amount (out-of-network) Machine-Readable Files (MRFs) has been delayed from January 1, 2022 to July 1, 2022. And the Rx pricing MRF is on hold until further rulemaking is completed. See this post on Diving into the Details: What You Need to Know About the Machine-Readable Files Mandate

Self-Service Price Estimation Tool – Additional Time of Deliver Strategic Member Experience

CMS resolved the conflict between requirements under the No Surprises Act to provide a price comparison tool by 1/1/22 and Transparency in Coverage to provide an internet-based self-service tool by 1/1/23. Accordingly, CMS will now defer enforcement of the NSA requirement to make a price comparison tool available until 1/1/23.

Opportunity to Leverage Delay of Price Transparency Mandate – Challenges, Issues, & Opportunities

Smart health plan leaders will take advantage of recent delays to differentiate their organizations beyond merely ‘checking the box’ of government compliance. To help with that approach, the HealthCare Executive Group has hosted two Focus Area Roundtable on Price Transparency and has a 3rd opportunity for health plan leaders to differentiate their organizations beyond merely “checking the box” but rather taking an approach to improve the overall experience of their plan members.

On Thursday, September 23rd at 4:00 PM ET, our Focus Area Partner for Price Transparency HealthSparq will facilitate the 3rd Focus Area Roundtable. In this discussion, the following topics will be discussed:Delay to Price Transparency Mandate. No Surprises Act (NSA) and Transparency in Coverage (TiC). Machine-Readable Files. Self-Service Price Estimation Tool. HealthSparq.

  1. How have you adjusted your plans based on CMS’ recent changes regarding the delivery of Machine-Readable Files?
  2. What are the challenges you are encountering regarding compliance with and/or strategically positioning your price comparison tool(s) beyond just a ‘check the box’ approach?
  3. Who’s driving the process to comply with and/or strategically position your price comparison tool requirements?

Opportunity to Meet Others & Ask Questions of Experts on Price Transparency

Our Focus Area Roundtables are 45-minute sessions where all participants get to introduce themselves, meet others dealing with similar challenges, issues, and opportunities, and ask questions of experts intimately involved with addressing specific priorities. Read the recaps of earlier price transparency roundtables here, here, and here and check out upcoming roundtables on other priorities identified by healthcare executives and consider joining those roundtables.