The Transparency in Coverage (TIC) deadline for Machine Readable Files is rapidly approaching. As a reminder, beginning July 1st, 2022, self-funded health plans will be required under Transparency in Coverage rules to post Machine-Readable Files on a publicly facing website. Below is the important information you need to know to prepare for the upcoming compliance deadline:
1. What are the TIC MRF requirements?
On November 12, 2020, the Departments of Health and Human Services, Labor, and the Treasury (the “Departments”) finalized the Transparency in Coverage Rule that requires health insurers to create and post publicly available MRFs that include INN negotiated payment rates and historical OON allowed rates for covered items and services. In addition:
– The MRFs must be available on a public website
– The MRFs must be updated monthly
NOTE: The Departments consider “monthly” to refer to reasonably consistent periods of approximately 30-days but aren’t specifying a particular day of the month.
– The MRFs must be accessible free of charge
– The site can’t require the user to establish a user account, password, or other credentials
– The site can’t require the user to submit any personal identifying information such as a name, email address, or telephone number
Plans have flexibility to publish the files in the locations of their choosing based upon their knowledge of their website traffic and the website location where the MRFs would be readily accessible by the intended users.
2. Will we host the required MRFs on behalf of its plan groups?
Yes, we will create, generate, and publish files on behalf of the client groups for which we have rates in our systems. Please note that your OON MRF may be “empty” (not contain any rates) if your plan hasn’t incurred the minimum number of OON claims during the reporting period.
3. Where will we publish the MRFs? On our existing public website?
The MRFs will be posted on a separate publicly available site hosted by us, which will be available by July 1, 2022. A link to this site will be added to our existing public website. Employers can post the link below on their website to satisfy the Plan’s obligation to post their MRFs.
RGA Link: https://sawus2prdticmrfrgawa.z5.web.core.windows.net/
NOTE: If you attempt to access the link prior to July 1, 2022, it may not be available. Please check back on or after July 1, 2022.
4. Do I need to add a link on my website to where you host the MRFs?
Yes, you are required to post a link on your public website to where we host your MRFs. If you don’t have a public website, we recommend you discuss the requirement with your company’s legal counsel. Please note that we won’t create a website for your company.
5. Which Machine Readable Files are you hosting?
The original TIC mandate released 1/11/2021 included three MRFs:
– INN Rate File
– OON Allowed Amount Rate File
– Prescription Drug Cost File
However, in July of 2021, CMS deferred the Prescription Drug Cost File indefinitely, pending additional rule making. The rationale behind deferring and potentially removing the Prescription Drug Cost file is due to overlapping requirements. There is currently a mandate for reporting prescription drug costs that would make this file redundant. Should the Prescription Drug Cost File requirement be reinstated, we will keep you apprised on what to expect.
6. Will your plan information be included in the MRFs?
The MRFs will include information only for plan years that became active or renewed on or after January 1, 2022.
– If your plan hasn’t yet become active with us, then your plan information won’t be included in the MRFs until after your plan becomes active, as follows:
– For INN MRFs, this will be within approximately one month after your plan becomes active.
– For OON MRFs, this will be once your plan has reached the required reporting timeline. Because this reporting timeline is 3-6 months in the past and MRFs are produced monthly, it takes approximately 4 months after your plan becomes active with us for OON data to start showing up.
– If your plan is active but hasn’t yet renewed with us (for example, if your plan renews on October 1, 2022), then your plan information won’t be included in the MRFs until after your plan renews. For both INN and OON MRFs, this will be within approximately one month after your plan renews.
7. Your plan has other plans that we don’t administer, will that data be included in the MRFs that you produce?
No. The MRFs will include data only for plans which we administer. It is up to you to coordinate with any other plan administrators you may have. We also cannot include data from a previous carrier in MRFs.
8. Can you download the MRFs and look at them yourself manually? Will we help you decipher the contents?
Please note that the mandate specifies the files must be “machine-readable”, not “human-readable”. You can download the files, but in order to understand them you’ll need software that can read JSON files.
9. Will we send you a copy of the MRFs? Do you need to host the MRFs on my own site?
We won’t send you a copy of the MRFs. We will host the files on its own public website here. You may download the MRFs from there if you want, but since we are already hosting them on your behalf, you aren’t required to download the files or post them on your own site. You are required, however, to post a link on your website to where we host the MRFs.
10. How long will we retain MRFs?
We are able to produce historical reporting showing MRFs were posted timely each month for audit and compliance purposes. However, please note that only the most recent month’s MRFs will be available to pull. We won’t be providing historical MRFs publicly or providing them by request.
11. Will we host MRFs for clients post-termination?
We will leave your last active file(s) up for up to three months after your termination date.
12. What about the Consumer Price Transparency Tool Required under Transparency in Coverage Rules?
The TIC requirement for an internet-based Consumer Price Transparency Tool that includes personalized information regarding enrolled members’ cost-sharing responsibilities for covered services and items applies to Plans effective on or after January 1, 2023. We will have further information about our support for the Consumer Price Transparency Tool as the compliance deadline approaches.