July 1 Deadline for Transparency Machine-Readable Files Posting Requirement

As a reminder, on Friday July 1, 2022, with respect to plan or policy years beginning on or after January 1, 2022 through July 1, 2022, group health plans (self-funded and insured) and health insurance issuers are required to publicly disclose in-network rates and out-of-network allowed amounts and billed charges in two machine-readable files on a public website of the plan (or TPA if the plan does not have a website) or issuer.  The machine-readable files must be accessible without the use of any log-in or password requirements.

For 2022 plan years and policy years beginning subsequent to July 1, plans and issuers should post the machine-readable files in the month in which the plan year (in the individual market, policy year) begins (e.g., for a plan year that begins October 1, 2022, the plan would not have to post the two files until October 1).