"While third parties can implement many of the pricing transparency measures, plan fiduciaries must ultimately ensure compliance. As compliance deadlines for new pricing transparency requirements for group health plans draw near, plan sponsors will need to use the second half of 2021 to prepare.... [T]he No Surprises Act includes a myriad of transparency and disclosure requirements that take effect in 2021 and 2022. Plan sponsors will need to work closely with service providers and issuers to ensure that group health plans are well-positioned to comply. "