Transparency in 2026 and beyond

The Baldwin Group

The Consolidated Appropriations Act (“CAA”) represents the most significant push for transparency in employer-sponsored health plans since the Affordable Care Act (ACA). The law, which incorporates the No Surprises Act and Transparency in Coverage (TiC) rules, mandates sweeping changes on employer-sponsored health plans, forcing the disclosure of previously hidden cost and quality information. Plan sponsors now face an actively enforced compliance calendar that includes the Gag Clause Prohibition Compliance Attestation (“GCPCA”), detailed Prescription Drug Data Collection (“RxDC”) reporting, and full deployment of a member Price Comparison Tool for all covered services. Looking ahead, employers should monitor the status of the deferred Advanced Explanation of Benefits (AEOB) and Good Faith Estimate (GFE) process.

The primary focus for plan sponsors is now mitigating ERISA fiduciary risk by mastering CAA requirements and clearly defining the compliance boundaries of their service providers (Third-Party Administrators, carriers, etc.)  Plan Sponsors should implement a proactive monitoring strategy to ensure these complex compliance functions are properly being executed.

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