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Transparency in Coverage
Machine-Readable Files

Updated June 8, 2022

On November 12, 2020, the Federal government issued the Transparency in Coverage (TiC) Final Rule. Under this Rule, group health plans must create and publish machine-readable files (MRFs) that contain detailed pricing information, including:

  1. Network negotiated rates for all items and services
  2. Historical payments to, and billed from charges from, out-of-network providers

Group health plans are required to make these files available to the public from an open-access internet website effective July 1, 2022.

How Allied will support its clients

By July 1st, Allied will create and publish the MRFs for the medical plans that Allied administers (at this time the pharmacy MRF are delayed pending additional rulemaking).

Allied will host the files on each client’s behalf to a publicly accessible MRF Hub website at alliedbenefit.sapphiremrfhub.com* and will update the files on the first of each month.

* Please note, the link will not be active until July 1, 2022.

What Employers need to do

To ensure compliance with the TiC MRF Rule requirement, employers should be prepared to post the MRF Hub website link (alliedbenefit.sapphiremrfhub.com) on their own company's public-facing website (not on an internal site or benefits portal where it is available solely to the employees or plan participants). The link will become active July 1, 2022. There is no formal guidance on how or where the link should be displayed on the website.

Along with the link, employers may include the following recommended language:

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to access and analyze data more easily.

FAQs

What is a machine-readable file?

A machine-readable file (MRF) is a digital representation of data or information in a file that can be imported or read by a computer system for further processing without human intervention. These files follow the Centers for Medicare & Medicaid Services (CMS) defined layout and are in the CMS-approved format (JSON). These files are not meant for a consumer-friendly search of rates, benefits, or cost-sharing.

Stated by the CMS, the primary intent for releasing these cost data files is to provide opportunities for detailed research studies and data analysis, as well as offer third-party developers and innovators the ability to create private-sector solutions to help drive additional price comparison and consumerism in the health care market.

What are the requirements?

Under the Transparency in Coverage Final Rule, group health plans must create and publish machine-readable files (MRFs) that contain detailed pricing information, including:

  1. Network negotiated rates for all items and services
  2. Historical payments to, and billed from charges from, out-of-network providers

Group health plans are required to make these files available to the public from an open-access internet website effective July 1, 2022.

Where will the files and links be posted?

Allied will host the files on each client’s behalf to a publicly accessible MRF Hub website at alliedbenefit.sapphiremrfhub.com and will update the files on the first of each month.

When will the files be available?

The files will be available in the MRF Hub by July 1, 2022.

How often will data be updated?

The regulation requires the files to be updated monthly. As such, Allied will update the files on the first day of each month.

What if an employer does not have a publicly available website?

The rule requires the group health plan (the employer) to make available on a publicly accessible website the required machine-readable file(s). While the website need not be that of the group health plan itself, it is unclear how the group health plan would disclose the location of these machine-readable files in the absence of a website. To that end, any employer without a website should discuss the matter with its own legal counsel or technical resources.

Please note: Federal guidance regarding the Transparency in Coverage Rule and the Consolidated Appropriations Act, which includes the No Surprises Act, continues to be revised and updated. Please refer to publications managed by the Departments of Labor, Health and Human Services (HHS), and the Treasury for the latest legislative and regulatory updates. The information provided reflects Allied’s current plans as of the date of this publication. This guidance is for general informational purposes only and does not constitute legal advice. Allied recommends its clients and Plan Sponsors consult their legal counsel to ensure their plans are compliant with the applicable laws.