Healthcare Transparency Updates 

Federal agencies recently provided new guidance and requests for information to strengthen the implementation and enforcement of healthcare transparency rules as directed by Trump’s Executive Order. This does not change anything specific to employer compliance obligations but has the potential to provide further access to healthcare spend data. The guidance and requests for information (RFIs) can be found here and are summarized below.

• Machine-Readable Files. The Departments of Labor, HHS, and Treasury introduced Schema Version 2.0 for machine-readable files under the Transparency in Coverage Final Rule, aiming to reduce file size and improve clarity by eliminating duplicative data. In addition, an RFI was issued to gather input on prescription drug machine-readable files, which are currently delayed pending further guidance. The RFI focuses on implementation challenges and potential alternatives and suggests regulations to implement the prescription drug portion of the machine-readable files requirement are in the works.  

• Hospital Price Transparency. CMS issued updated guidance for hospitals, requiring actual dollar amounts in pricing files instead of estimates. CMS also issued an RFI to gather input on how to increase compliance and ensure that accurate and complete data is shared

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