Compliance Corner

May 24, 2022

State and Territory Updates



Podcast Episode 124: Hospital Prices and Group Health Plan Costs

In this episode, Suzanne Spradley and Chase Cannon discuss hospital prices and their impact on employer group health plans. Suzanne describes this issue as it relates to the new transparency in coverage rules. Suzanne and Chase review a recent study that reviews hospital prices nationwide, including Medicare-certified, short-stay and other facility types. Suzanne discussing the findings of the study, price consistency among the various states, and what it all might mean for employer-sponsored group health plans. Suzanne and Chase close with a discussion of what other means might be available for controlling healthcare costs.

Periodically, NFP's legal experts make the subject of compliance personal for a wide audience. By breaking down the daunting details of emerging policies and bridging the gap between legislation and what it means for the listener, Chase Cannon and Suzanne Spradley make compliance issues relatable and relevant. Visit our Soundcloud page for the most up-to-date episode.

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June Get Wise Wednesdays – Register Now

Topic: Controlled Groups: Confusing Topic, but Important to Benefits Compliance

The structure of an organization can significantly impact health and welfare benefits compliance. In this webinar, we’ll review the basic types of IRS controlled groups and how controlled group status affects compliance with laws such as the ACA, COBRA and Section 125 and 105 nondiscrimination rules. The presentation will also discuss special compliance considerations that may arise from changes in controlled group status (e.g., through mergers and acquisitions).

Time: June 15, 2022
2:00 to 3:00 p.m. CT (3:00 to 4:00 p.m. ET)

Register Now

This program is pending approval for 1.0 (general) recertification credit hours toward PHR, SPHR and GPHR recertification through the HR Certification Institute. For more information about certification or recertification, visit the HR Certification Institute website at

Note: Those listening to a recorded webinar will not be eligible for credit.

Reminder: Public Disclosure of Provider Reimbursement Rates Begins July 1, 2022

On July 1, 2022, enforcement of the machine-readable file requirement of the Transparency in Coverage (TiC) final rule begins. Under the rule, non-grandfathered group health plans and insurers must publicly post machine-readable files that disclose in-network provider negotiated rates and historical out-of-network allowed amounts and billed charges for plan years beginning on or after January 1, 2022. (Enforcement of the prescription drug rate file requirement is postponed pending regulatory review.)

The files must be in a specified format, updated monthly and posted on a public website accessible to any person free of charge. No conditions can be imposed to access the files, such as establishing a user account or password or submitting personally identifiable information.

Group health plan sponsors should be in consultation with their insurers or third-party administrators to ensure timely compliance with the July 1 deadline. For fully insured plans, the legal obligation can be contractually transferred to the insurer. For self-insured plans, the sponsor remains liable for TiC compliance even if a TPA contractually agrees to assist with the creation and implementation of the files.

For further information, please see:

Transparency in Coverage Final Rule »
FAQs on ACA and CAA, 2021 Implementation »