July 1 Deadline for Transparency Machine-Readable Files Posting Requirement

Groom Law Group, Chartered

As a reminder, on Friday July 1, 2022, with respect to plan or policy years beginning on or after January 1, 2022 through July 1, 2022, group health plans (self-funded and insured) and health insurance issuers are required to publicly disclose in-network rates and out-of-network allowed amounts and billed charges in two machine-readable files on a public website of the plan (or TPA if the plan does not have a website) or issuer. The machine-readable files must be accessible without the use of any log-in or password requirements.

For 2022 plan years and policy years beginning subsequent to July 1, plans and issuers should post the machine-readable files in the month in which the plan year (in the individual market, policy year) begins (e.g., for a plan year that begins October 1, 2022, the plan would not have to post the two files until October 1).

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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