New Price Transparency Rules for Health Plans: Key Issues for Plan Sponsors, Service Providers, and Insurers

Requirements and New Mandates, Administrative and Operational Challenges, and Next Steps to Promote Compliance

Recording of a 90-minute premium CLE video webinar with Q&A

Conducted on Wednesday, February 3, 2021

Recorded event now available

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Course Materials

This CLE course will guide employee benefits attorneys, plan sponsors, and plan administrators and service providers through new price transparency rules for health plans. The panel will discuss key provisions of the final rule; the rule’s impact on plan sponsors, insurers, and service providers; requirements and new mandates; administrative and operational challenges; and best practices to promote compliance.


On Oct. 29, 2020, the Departments of Health and Human Services, Treasury, and Labor jointly issued a “Transparency in Coverage” final rule. The rule imposes significant transparency requirements and new mandates on group health plans and insurers in the individual and small group markets.

Under the final rule, affected plans and insurers must disclose cost-sharing estimates, negotiated rates for in-network providers, out-of-network allowed amounts, charges, and drug pricing information. The rules are subject to enforcement under the ACA, requiring strict operational procedures to promote compliance and help avoid state and DOL enforcement actions.

The final rule does not change existing privacy and security requirements under HIPAA or other applicable state and federal laws. Employee benefits attorneys, plan sponsors, and insurers must implement procedures aligned with the mandates under the final rule while maintaining compliance with other applicable state and federal laws.

Listen as our panel discusses key provisions of the final transparency in coverage rule, new requirements and mandates, administrative and operational challenges, and best practices and next steps for plan sponsors, insurers, and service providers.



  1. Key provisions of the new price transparency rules
  2. Application of disclosure requirements to health plans
  3. Disclosure of cost-sharing information
  4. Disclosure of negotiated in-network and out-of-network rates
  5. Drug price transparency requirements
  6. Shared savings in the medical loss ratio
  7. Best practices and next steps for plan sponsors, insurers, and service providers


The panel will review these and other key issues:

  • What are the key provisions of the new price transparency rules?
  • How do the new rules impact health plan sponsors, insurers, and service providers?
  • What are the disclosure requirements for cost-sharing, in-network rates, out-of-network amounts, and shared savings?
  • What potential shared savings are available under the revised MLR regulations?
  • What are the next steps and best practices to maintain compliance with the new rules?


Hall, Margaux
Margaux J. Hall

Ropes & Gray

Ms. Hall is a leading lawyer in drug pricing, managed care and value-based payment arrangements. She brings to clients...  |  Read More

Williams, William
William O. Williams, II

Insurance Regulation Practice Group Leader
Frost Brown Todd

Mr. Williams practices administrative and regulatory law in the areas of insurance and health care, representing health...  |  Read More

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