Legal Obligation for Self-Insured Employers
Self-insured employers can satisfy compliance obligations by providing a link to the location of the required files on their public website. They can also enter into a written agreement for another party to make the required information public. According to the “non-duplication” rule, as long as the required information is made available, it doesn’t need to be duplicated. SBMA can act as this other party and plans to update user agreements as they are renewed. Sponsors of a MEC plan should provide a button on their website designated “Transparency in Coverage,” followed by “Click here to access information about our company’s group health plan’s payments to, and billed charges from, providers.”
Take the Necessary Steps to Remain Compliant
We recommend that employers and sponsors that do not have a website instead provide a notice to their plan participants that information about the company’s group health plan’s payments to and billed charges from providers is available on the SBMA website. The transparency in coverage rules is part of a more extensive set of transparency rules that affect every aspect of health care in the United States. Transparency in coverage rules is the first to affect employers and employer-sponsored group health plans. For more information and guidance, contact the SBMA compliance department with any questions you may have.