The Transparency in Coverage Rule (TiC) of 2020 requires health insurance issuers and health plans to publicly disclose certain items, including in-network negotiated rates and individualized cost-sharing information. Enforcement of this rule was delayed pending conflicting regulations and to permit time for entities to prepare systems to meet the machine-readable file requirement. Read our most recent blog for more details on plan compliance with the TiC.
This summer CMS issued their first civil monetary penalties under the TiC to two Georgia-located hospitals, one in the amount of $833,180, and the other at $214,320. What didn’t these hospitals do?
In short, they failed to (1) follow the TiC regulations with respect to providing transparency of pricing in a user-friendly, prominent manner in the required machine-readable file; and (2) correct such errors after receiving a Corrective Action Plan (CAP) from CMS, therefore remaining noncompliant.
Don’t be like these hospitals.
Good faith reasonable efforts speak volumes. Know your plan; know your obligations; make necessary changes to comply with regulations; shore up your contracts as needed; document your efforts; and, for the love — if you do all this — and still fail…correct errors.
Don’t ignore the government. Otherwise, it will cost ya.