UPDATED: JULY 14, 2021
On July 1, 2021, the Centers for Medicare and Medicaid (CMS) issued additional regulatory guidance for the No Surprises Act. The following information outlines the key implications for self-insured employers and their TPAs:
- No changes or delays in the Transparency in Coverage requirements around Machine-Readable Files (MRF’s) for 1/1/22.
- Additional guidance will be issued later this year for the online price comparison tool for 1/1/22.
- With no indication of delay, Bluebook is moving forward with our partners as planned to ensure readiness for these “final” requirements for 1/1/22.
[Originally published on May 27, 2021, this blog provides an overview of the Transparency in Coverage and No Surprises Act mandates, a breakdown of the requirements and associated deadlines, and the impact on health plans, TPAs, and self-insured employers.]
In 2007, long before most people had even heard of healthcare price transparency, Healthcare Bluebook launched with cost transparency as its foundation.
Our purpose was, and is, simple: to Protect Patients, clinically and financially, by exposing the true quality and cost of healthcare. Why? Because every patient should have access to the truth and confidence in their healthcare choices. Choosing high-quality Fair Price™ doctors and facilities is the first step toward lowering healthcare costs and improving quality of care.
Today Bluebook serves a diverse group of clients, from self-insured employers, brokers and consultants, third-party administrators (TPAs), health plans, and strategic wellness navigators with an offering that extends far beyond Fair Price estimates to include quality rankings for doctors and hospitals powered by the largest healthcare quality and cost dataset in the United States.
Now, more than a decade after Bluebook began, healthcare price transparency is front and center in Washington D.C., which has placed the onus firmly on hospitals, health insurers, and self-insured plans by requiring compliance with the Transparency in Coverage rules and No Surprises Act, part of federal healthcare transparency initiatives that began with the 2019 Executive Order on Health Care Price Transparency. (The first compliance mandate, Hospital Price Transparency, required hospitals to disclose pricing information by 1/1/21.) The next wave of requirements for health plans and self-insured employers is due 1/1/22.
Not as easy as it sounds
While the concept of price transparency sounds simple, in fact, the process is complex with many moving parts and interdependent variables related to information that providers and payors are reluctant to disclose. Compliance requirements are extensive and include the provision of online shopping tools with out-of-pocket calculators and detailed pricing, advanced EOBs (Explanation of Benefits), provider directories, and public hosting of machine readable files, to name a few.
Self-insured employers are required by law to meet these compliance mandates starting 1/1/22, and will demand that their third-party administrators TPAs and administrative services only (ASO) plan partners deliver a fully compliant solution on their behalf. As we approach the halfway mark of 2021, the clock is ticking.
Now for the good news
Over the past two years, federal legislators and policy makers have called upon Bluebook’s experts to share input during the rule-making process. Once the final rules were announced, our team began researching every nuance of every rule to become fully fluent in the final transparency mandates.
As a result, we now offer Bluebook Comply™, a compliance solution solely focused on ensuring our clients and partners meet all deadlines for the Transparency in Coverage rules and No Surprises Act.
A strategic opportunity beyond compliance
It’s no secret that drastic variations in the healthcare system can lead to inappropriate, expensive, and even unnecessary care that impacts benefit plan costs. And though compliance with these rules will carry some administrative burden and cost, fulfilling the requirements also has the potential to influence the way enrolled members make healthcare decisions, which can dramatically reduce healthcare costs for everyone when care is received from high-value doctors and facilities.
Using Bluebook’s robust database to power the required online shopping tools conveys a more realistic picture of the scale and financial impact of price variations—even for in-network providers—to give individuals more information to guide their healthcare choices.
What happens next?
The requirements present a prime opportunity for TPAs to transform the burden of compliance into a strategic advantage by empowering clients with a user-friendly solution that helps them make informed decisions that drive savings and high-quality care.
Bluebook Comply gives clients preferred access to our premium easy-to-use navigation solution that includes provider quality metrics, engagement and incentives programs, and concierge service through Bluebook CareConnect™—proven value that helps offset the cost of compliance.
So in the end, even with all the hoops to jump through, compliance can be a win-win for everyone.