Oct. 6, 2021

Update: Transparency in Coverage and Consolidated Appropriations Act

On Aug. 20, the Departments of Labor, Health and Human Services, and the Treasury (“the Departments”) issued guidance in the form of Frequently Asked Questions to address the implementation of the Transparency in Coverage Final Rule, as well as the implementation of certain provisions of the Consolidated Appropriations Act, 2021 (CAA). 

Specifically, the Departments wrote that they would delay enforcement of certain provisions, including:

• The Transparency in Coverage Machine-Readable Files requirements
• The CAA’s Price Comparison Tool requirements 
• The CAA’s Advanced Explanation of Benefits requirements
• The Pharmacy Benefit and Drug Cost Reporting requirements

Our cross-functional teams working on Transparency in Coverage and the CAA are evaluating this new guidance to determine how it affects the implementation work. 

Review the latest information and updates .

While we are providing these highlights of key aspects of the requirements, we do not provide groups with legal or compliance advice. Group customers must contact their legal advisors if they have questions about these laws and regulations, what they require and how they will affect their benefit plans.