There are a number of new health cost transparency obligations imposed upon employers that offer group health plans to employees. Although these rules have been overshadowed by COVID-19, these provisions will have a significant impact on health plans, similar to the impact of the Affordable Care Act (ACA). Although employers may engage third parties to fulfill some (but not all) of these requirements, employers that sponsor group health plans are ultimately responsible for compliance. Thus, it is important to understand the rules including understanding the existence of, and differences between, the “Transparency in Coverage” rules and the collection of various but separate transparency rules that are part of Consolidated Appropriations Act (CAA). Use this high-level matrix to begin understanding the big picture, the requirements, and next steps and stay tuned for updates as this evolves.
