"[The FAQs delay] several of the most challenging 2021 and 2022 compliance requirements under the Consolidated Appropriations Act, 2021 (CAA) and the [ACA]: so-called 'advanced explanations of benefits' (EOBs) providing good-faith estimates of the out-of-pocket costs for scheduled medical services; a 'price comparison tool' to enable participants to compare cost-sharing amounts for specific network providers; extensive drug cost information that was to have been reported to the federal regulators in December 2021; and public pricing disclosures related to in-network rates, out-of-network allowed costs, and prescription drug prices."

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