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Surpassing Mere Compliance: Including Reference Based Pricing


Jan. 20, 2022
Recorded Online


  • Steve Cyboran, ASA, MAAA, FCA, CEBS, actuary and strategy consultant
  • Wes Rogers, Humaculturist® and strategy consultant
  • Jack Towarnicky, LLM, JD, MBA, CEBS, strategy and compliance consultant


This series addresses how to strategically leverage the No Surprises Act to create a competitive financial advantage for both the plan sponsor and plan participants. This session focuses on Surpassing Mere Compliance and includes Reference Based Pricing as an example of a strategic response to avoid compliance with many aspects of the No Surprises Act.

Surpassing Mere Compliance Takeaways

During this session, participants will learn:

  • The No Surprises Act doesn’t eliminate all “surprises”
  • The No Surprises Act is likely to be inflationary
  • Mere compliance won’t reign in costs, will increase administration, and may increase litigation risk
  • Using Reference Based Pricing as one example of strategic actions you can take to:
    • Avoid what can be avoided
    • Use tax preferences to finance what can’t/shouldn’t be avoided
    • Communicate all negatives as the result of compliance
    • Inform/educate consumers (before they become patients)

More Information, How to Register

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