Transparency in Coverage: Machine-Readable File Posting
June 15, 2022
By July 1, 2022, the Transparency in Coverage (TiC) Final Rule mandates the posting of “machine-readable files” on the public website of group health plans and health insurance issuers. A machine-readable file is a digital representation of data and information that can be imported or read by a computer system for processing without human intervention. This posting is not intended to represent participant-friendly consumer pricing – that transparency tool will be required in 2023 and beyond; instead, this information must be available to the general public. The machine-readable data file must include plan options, billing codes and rates/allowable amounts for both in-network and out-of-network coverage. These files are expected to be updated on a monthly basis going forward.
Do you, as an employer plan sponsor, have to create these files? No. But depending on the type of plan you sponsor, you still have varying degrees of responsibility. See below:
Action Items for Fully-Insured Plans
- Fully-insured carriers are required to post de-identified machine-readable files on their own public-facing website.
- If you sponsor a fully-insured plan, you (as employer plan sponsor) have no responsibility to post these files as long as your carrier is doing their job.
- If you haven’t yet received communication from your carrier, check with your Cottingham & Butler benefits team to ensure that your carrier is posting the required files on a public-facing website in a timely manner.
Action Items for Self-Funded Plans
- Self-funded employer plan sponsors do not have to post the actual files – your TPA (or other vendor) should post the machine-readable files.
- However, self-funded employers must post a link to your TPA’s posting of machine-readable files on your public facing website.
- Remember, this cost-sharing data must be available to the general public. So, the link to your TPA’s posting should be posted in a conspicuous area of your publicly-accessible website (not intranet). We recommend posting the link in your “About Us” section or at the bottom of your landing page. You may also create a specific tab for the link to these files.
- The link should be described in a brief manner, with the following language: [Name of TPA/vendor] creates and publishes machine-readable files on behalf of [name of health plan]. To link to the files, please click on the URL provided: [insert URL].
- If your organization does not have a publicly-accessible website, contact your Cottingham & Butler benefits team for alternative options.
- Step-by-step checklist:
- If you have not yet received the link to the posting from your TPA or vendor, check with your Cottingham & Butler benefits team receive the URL and your TPA’s expected posting date.
- After obtaining the URL, work with your IT professional to post the link using the location and description suggested above.
- Once the link is posted and verified active, your responsibility is complete.
This Compliance Alert is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.