Update for machine-readable files transparency requirement

The machine-readable file (MRF) requirements are part of the Transparency in Coverage final rule issued in 2020. The MRF rules require group health plans (primarily medical/Rx coverage) to disclose pricing data on covered items and services through three separate files:

1. In-network contract rates,
2. Historical out-of-network allowed amounts, and
3. In-network negotiated rates and historical net prices for all covered prescription drugs (the “Rx MRF”).

The compliance requirements began in 2021, but the federal agencies delayed the effective date for the Rx MRF until further notice. The federal agencies recently issued FAQs rescinding the prior enforcement delay, but the FAQs indicate the agencies will communicate the effective date for compliance in future guidance (i.e., the effective date is “TBD” but coming). The future guidance will also include certain other technical requirements.

This Alert summarizes the general machine-readable file requirement, compliance effective dates and the recent updates, and next steps. It is appropriate for all employers.