On Aug. 20, the Centers for Medicare & Medicaid Services’ Center for Consumer Information and Insurance Oversight issued frequently asked questions (FAQs) on the several price transparency requirements related to health plans and included in the No Surprises Act.
The following provisions have effective dates that have been delayed and may impact the implementation of the No Surprises Act:
- Good Faith Estimate
- Advanced Explanation of Benefits
- Health Plan Machine Readable File for In/Out-of Network Rates
- Health Plan Price Transparency Tool
- Health Plan Machine Readable Pharma File
The FAQs also address provisions related to health plan insurance identification cards, prohibition on gag clauses on price/quality data, the accuracy of health plans’ provider directories, continuity of care, grandfathered health plans, and reporting on pharmaceutical benefits costs. However, the FAQs do not change the effective date for any of these provisions. None of the FAQs address the separate hospital price transparency requirements.