The Department of Labor (DOL) released three model disclosure documents to be used in conjunction with the newly proposed rule for health care transparency, issued on November 15, see previously issued bulletin “Proposed Rule on Health Care Transparency to Affect Some Employer Plans”. The proposed rule would require health plans and insurers to disclose cost-sharing estimates on health care items and services to individuals when requested, either online or in writing; and provide in-network provider-negotiated rates and historical out-of-network permitted amounts to be available on insurers’ websites.
To assist with the requirements of the transparency rule, the below model notices have been issued by the DOL to assist employers in complying with the proposed rule. The DOL has asked that any feedback on the model notices be provided no later than January 14, 2020.
- Proposed Transparency in Coverage Model Notice – This model would be used for health care vendors to provide an estimate of any required prerequisite items or services, and serve as a notice explaining the various restrictions that are applicable to an individual’s cost-sharing estimate.
- Proposed Negotiated Rate Data Elements – As part of the proposed rule, insurance vendors must disclose in-network provider negotiated rates through an automated file feed posted on an internet website. The negotiated rate is the amount an insurance vendor has contractually agreed to pay an in-network medical provider for covered services. This model includes a table that lists the required data that an insurance vendor would be required to provide within each file feed.
- Proposed Allowed Amount Data Elements – As part of the proposed rule, insurance vendors must disclose certain information to the public, including current and historical permitted charges for out-of-network providers and services, through an automated file feed posted on an internet website. This model includes a table that identifies the required data that an insurance vendor would be required to include in each allowed file feed.
Read the Health Care Bulletin for additional information pertaining to the three model notices, as well as a link to each document to review. The transparency rule is still only proposed, and is not in effect at this time. If the transparency rule is finalized, additional information will be provided for clarification.
Contact your Cowden representative for more information on this or other compliance issues.