Good afternoon,

This is to inform you of recent legislation that is going into effect that does require your participation to meet compliance guidelines.

The Transparency in Coverage law was passed November 2019 to help consumers know the cost of a covered item or service before receiving care. It’s being implemented in 3 phases. The first phase will go into effect 7/1/2022 with the remaining phases effective years 2023 & 2024.

The first phase is not user friendly and will only be used for researchers and software app developers to help consumers better understand the cost of their care. This phase requires posting of a link to machine readable files on your public website. The link is issued by your healthcare carrier and needs to be anywhere on your website as long as it does not require a password and login to view it.

Below is an overview on how your plan is affected by this first phase.

Below is what your carrier has sent out recently. I’ve highlighted the important information and action steps.

The ‘Full Text’ below from UHC was sent out Plan Administrators on existing All Savers and UHC Level Funded groups recently. I’m copying the text and add/or highlighted important information.

High Level Overview:

To comply with the Transparency in Coverage Rule, self-funded customers must post UnitedHealthcare’s transparency-in-coverage.uhc.com link on their own publicly available website. This is a new law to provide transparency in healthcare pricing and is being implemented in phases.
Once the link is posted to a publicly available site, the employer responsibility is complete.
If a group does not have a publicly available website, please discuss available options with legal counsel.
Please remember that the machine-readable file content will not be available until July 1. Suggestion is to post using the suggested language below (in red text) transparency-in-coverage.uhc.com link, which will be updated on UHC’s side as appropriate
MRFs are not the member-friendly consumer price transparency tool that will be available in 2023 and 2024. However, similar ‘member-friendly’ pricing transparency information is currently available on our member website.

Full Text:

Machine-readable files required on public sites by July 1, 2022, for Transparency in Coverage

As the initial enforcement date of July 1, 2022, approaches for posting the machine-readable files (MRF) under the Transparency in Coverage Rule, UnitedHealthcare is providing an overview of requirements for health insurers and group health plans, including self-funded, UnitedHealthcare Level Funded, Oxford Level Funded and All Savers Alternate Funding clients.

UnitedHealthcare is committed to supporting the Transparency in Coverage Rule by making MRFs available for UnitedHealthcare self-funded customers on July 1, 2022.

Self-funded and level funded plans are required to make the MRFs publicly accessible. This requires providing a link to MRFs prepared by the insurer/TPA.

To meet this requirement, MRFs will be posted monthly on transparency-in-coverage.uhc.com. This location is publicly available and accessible to all – no authentication is required.

While these files are accessible to all, the file itself is large, written in JSON – a machine-readable language – and not easily interpreted or searchable.

MRF for self-funded and level funded plans
To comply with the Transparency in Coverage Rule, self-funded customers must post the transparency-in-coverage.uhc.com link on a publicly available website.

Important considerations and next steps
When the UnitedHealthcare MRF link is posted, it must be easily accessible without a login/password.
Prior to July 1, 2022, the UnitedHealthcare transparency in coverage website will display sample fully insured data. Company-specific information will not be displayed. Until July 1. Beginning July 1, the website will contain live data and MRFs in accordance with the requirements.
Brokers and employers should work with applicable teams prior to July 1 to ensure the transparency in coverage website is publicly accessible by the required date.
Brokers and employers may use the following language when posting the UnitedHealthcare transparency in coverage link:
UnitedHealthcare creates and publishes the machine-readable files on behalf of [add customer name]. To access the machine-readable files, please click here.
Once the link is posted to a publicly available site, the employer responsibility is complete.
Beginning July 1, 2022, employers may locate and view their MRF information. To do so:
Go to transparency-in-coverage.uhc.com
Search for the intended employer name
Associated MRFs will appear
Example: 2022-07-01_customer name_Choice-Plus_in-network-rates.json
MRFs will be updated monthly in accordance with requirements

Transparency in Coverage regulation requires self-funded employers to publish the link on a public site. If a self-funded group does not have a publicly available website, please discuss available options with legal counsel. UnitedHealthcare does not provide legal advice.

MRFs are not the member-friendly consumer price transparency tool that will be available in 2023 and 2024.

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