SIIA Submits Comments on the Proposed Transparency Coverage Rule
SIIA Provides Unique Perspective on Behalf of the Industry

January 29th – Earlier today, the Self-Insurance Institute of America, Inc. (SIIA) formally submitted comments to the Departments of Health and Human Services, Treasury, and Labor in response to a proposed regulation that would require self-insured plans – as well as fully-insured group and individual market plans – to disclose information about (1) specific cost-sharing information for plan- and policy-holders, (2) the health plan’s and policy’s negotiated in-network rates, and (3) health plan’s and policy’s “historical” payments to out-of-network providers.

SIIA’s comments to the proposed rule can be found here:

The full text of the Federal Departments’ proposed rule can be found here: https://www.hhs.gov/sites/default/files/cms-9915-p.pdf.

SIIA’s comments focus on over a dozen key points in relation to self-insured health plans and the important role that transparency and cost-sharing data play within the industry, including:

• Support for increased transparency of medical prices and cost-sharing information.
• The need for insurance carriers and medical providers to share plan data with plan sponsors and their designated agents in a timely and appropriate manner.
• The unique nature of self-funded plans, including network usage and reference-based pricing arrangements.
• The potential cost and administrative burdens of building disclosure platforms and storing data.
• How transparency can help reduce surprise medical bills.

The proposed rule, and subsequent public comments, are the first step in the formal rulemaking process. Once the Federal Departments review the comments, the Administration will determine whether and to what extent the proposed requirements should be modified. It is expected to take up to six to eight months before final regulations are issued. Once finalized, any new requirements would go into effect 1 year after publication, meaning an effective date sometime mid- to late-2021. However, the Federal Departments may delay the effective date further into 2022, as SIIA has proposed.

To learn more about this and other policy developments, please plan on attending the legislation/regulatory session featured as part of SIIA’s upcoming Self-Insured Health Plan Executive Forum, scheduled for March 16-18, 2020 in Charleston, SC. Event details can be accessed on-line at www.siia.org.

If you have any questions regarding the proposed rule, or SIIA’s comments, please contact Ryan Work, SIIA’s vice president of government relations, at rwork@siia.org or Chris Condeluci, SIIA Washington Counsel, at ccondeluci@siia.org.