NHC Comments on Transparency in Coverage

February 13, 2020

By Maddie Mason, Senior Associate, Policy

The National Health Council (NHC) submitted comments in response to the Department of Health and Human Services’ (HHS) proposed rule on Transparency in Coverage that was released on November 15, 2019. The NHC has long advocated for enhancements in transparency around out-of-pocket cost information for patients beginning at the plan selection process. Overall, the NHC applauded the progress that implementing this rule would make.

Some of the priorities in the NHC’s comments focused on assuring that greater transparency around both the cost of care and available options is available to patients. Patients need a clear understanding of what health care will cost them out of pocket when making health care decisions including picking insurance plans. In our Domains and Values, the NHC stated that in order to promote access to high-value care, as defined by patients, patients should be provided with adequate and transparent options for comprehensive and appropriate coverage and care.

The NHC also stressed that the most pressing need for people with chronic conditions is information about the cost-sharing requirements for products and services, and therefore we commended the Administration on their recent proposed rule to require insurers disclose cost-sharing information directly to enrollees. However, this proposed rule also requires plans to release negotiated rates and historical out-of-network rates, something we have also previously stated may not be the most useful information for patients and could lead to unintended consequences that could potentially increase the cost of care.

Previous CMS initiatives have started with specific items and services to reduce administrative burden and decrease consumer confusion. The NHC recommended that this rule also be rolled out slowly and grown by regularly updating and expanding the numbers and types of services that are searchable. To ensure the most pertinent and useful information is provided to patients, the NHC urged CMS to issue additional guidance that prioritizes beginning the process with the most used and “shoppable” products and services.

Increasing transparency in our complicated health care system in a manner that is easy for patients to understand and navigate is no small undertaking. Therefore, the NHC remains committed to working with policymakers in the Administration and Congress to create policies that will better inform patients of the costs associated with the services they need and about the financial implications they may face. The proposed rule requires consistency amongst payers, which is imperative for the its success, and we ask the Administration to incorporate input from and engage with stakeholders, especially people with chronic conditions and their families/caregivers, to ensure the success of this rule.