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P4ESC Letter to Agencies on Timelines and Obligations for Implementation of the Transparency in Coverage Final Rule (PDF)
Partnership for Employer-Sponsored Coverage [P4ESC] 
[Opinion] July 12, 2021 "[P4ESC is] very concerned about employers' ability to comply with the machine-readable files requirement by January 1, 2022... Because the employer does not own this network and drug pricing information, they must request it from the TPA/PBM or request that the TPA/PBM directly provide a compliant solution on the employer's behalf. The employer is at the mercy of the TPA/PBM's prerogative and schedule to obtain the information or provide a compliant solution." |
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