"[T]he new transparency mandates to disclose prices for 'shoppable services' are too complex to be effective for most participants. The best opportunity to facilitate consumerism is to make available an innovative Advanced Explanation of Benefits (A-EOB) ... Because [DOL] guidance on the A-EOB has yet to be issued, any organization that strategically implements their own version of a 'best practices' A-EOB could capture a competitive financial advantage -- reducing both employer spend and employee out-of-pocket costs -- by putting the economic purchasing power and decision-making in the participant's hands."

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