Internet Self-Service Tool Must Be Fully Implemented for 2024 Plan Years

The Transparency in Coverage Final Rule (TiC) requires non-grandfathered group health plans and carriers to make personalized out-of-pocket cost information available to participants through an internet-based self-service tool. The purpose of the self-service tool is to provide participants with real-time, accurate estimates of their cost-sharing liability for healthcare items and services from different providers, so they can shop and compare healthcare costs. The format may be like an explanation of benefits, but the participant receives the information prior to receiving care. 

Importantly, the TiC provided phased-in effective dates for the internet self-service tool requirement. For 2023 plan years, 500 “shoppable” items and services were required to be available through the tool. For plan years beginning on or after January 1, 2024, all items and services, including prescription drugs and durable medical equipment, must be made available. 

As a practical matter, most group health plan sponsors have arranged with their carriers to assist with fulfilling these requirements. Fully insured plans can contract with their carrier to assume liability for the tool disclosures. Self-insured plans can contract with TPAs or other vendors but remain responsible for satisfying the requirements. Accordingly, group health plan sponsors should consult with their carriers to ensure full implementation of the self-service tool requirement is on schedule. 

For further information, please review the Transparency in Coverage Final Rule, Fact Sheet, and our prior FAQ.