The compliance conversation with Jen Berman 

I'm going to be honest with you, the final Transparency in Coverage Rules for health plans surprised me — a lot.  Primarily because (1) they will lead to the public release of so much proprietary data, and (2) they will be costly to implement.

Of course, I knew something was coming and that it would be significant.  I just didn't know how significant—and the more I think about it, the more anxious I become to see what happens next.  This rule really does have the power to transform our industry.  It could also get so bogged down in "implementation wars" that its impact is scarcely felt.  Either way, this is something worth paying attention to.

So, what is it that I'm so fired up about?  The new rule can be broken into two key components:  the public disclosure requirements and the individual cost estimate requirements.  The public disclosure rule requires most employer-sponsored health plans to publish what they pay for benefits.  You read that correctly By plan years beginning on or after January 1, 2022, non-grandfathered group health plans will have to make publicly available files including all network negotiated rates, actual amounts paid towards out-of-network benefits (subject to limited privacy protections), and prescription drug costs net rebates and similar discounts.  That's a LOT of traditionally proprietary information flooding the marketplace.