Comment on Proposed Health Care Transparency in Coverage Regulations (January 29, 2020)
The Church Alliance submitted a comment letter to the Department of Health and Human Services (HHS) on January 29, 2020 in response to a request for comment on proposed regulations regarding Health Care Transparency in Coverage. The proposed regulations were issued jointly with the Departments of Labor and Treasury and would require extensive disclosure of specific in-network rates for every procedure covered by a self-insured health plan. The Church Alliance asked HHS to consider the unique circumstances of denominational health plans, namely the limited population to which they can be offered, and the burden the public disclosure requirements would place on such plans. The letter urged that church plans be exempted from the public disclosure requirements. If such an exemption cannot be made, the letter suggests that the rule to prevent unnecessary duplication be applied to self-insured denominational plans in the same way it is applied to insured plans, so that liability for failure to disclose information be placed on the third-party administrator of any denominational plan if they are also an insurer.