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Proposed Transparency in Health Coverage Rule: Potential Implications for Self-Insured Health Plans
Eversheds Sutherland, via JDSupra Link to more items from this source
[Guidance Overview]
Dec. 3, 2019

"The Cost Sharing Disclosure would mandate that Plans ... provide Participants with a clear estimate of their cost-sharing liability for covered items or services.... [T]he public disclosure of provider rate data may allow self-insured plans to compare their network rates to those offered to similarly situated plans in the same network and across competing network providers.... Note that the proposed rule would allow Plans to delegate responsibility and liability for Cost Sharing Disclosures to third parties, such as the Plan's TPA or ASO provider. While Plans may also delegate responsibility for Rate Disclosures to a third party, the Plan would still be responsible for any liability associated with non-compliance. "

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