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Consumers First Comments on Proposed Transparency in Coverage Rule


Consumers First, an alliance representing employers, providers, consumer organizations, and workers, recently submitted this comment letter to CMS regarding the Transparency in Coverage proposed rule. Consumers First believes price and quality transparency are critical to achieving higher value for health care consumers. While we agree on the importance of providing more transparency in coverage, the Administration’s efforts to affect consumer behavior through greater transparency are based on faulty assumptions regarding the primary audience for price transparency, which could undermine the ability of the rule to provide meaningful value to consumers seeking to reduce their health care costs and improve health care outcomes.

In the attached comments, we recommend changes to the underlying assumptions asserted in the rule and recommend several policy changes to maximize consumer benefit of the proposed rule and the Administration’s overall efforts to improve health care value and transparency. This comment letter focuses on the three key areas of the rule, and makes recommendations for further Administration action, not included in the rule:

  • Comments on Section II (A) of the rule: “Proposed Requirements for Disclosing Cost-Sharing Information to Participants, Beneficiaries, or Enrollees”
  • Comments on Section II (B) of the rule: “Proposed Requirements for Public Disclosure of Negotiated Rates and Historical Allowed Amount Data for Covered Items and Services from Out-of-Network Providers”
  • Comments on Section V of the rule: “Issuer Use of Premium Revenue under the Medical Loss Ratio Program: Reporting and Rebate Requirements”

Recommendations for further Administration action to support health care value efforts at the federal and state levels. Click the button below to download the Comment Letter.