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AAMC Submits Comments on Transparency in Coverage Proposed Rule

January 31, 2020

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CONTACTS
Mary Mullaney, Director, Hospital Payment Policies

The AAMC Jan. 29 submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to a proposed rule, Transparency in Coverage, which would require health insurers to publicly post negotiated rates for in-network providers and allowed rates for out-of-network providers.

The proposed rule would also require insurers to disclose patient-specific cost-sharing information for a covered item or service upon request from patients. CMS states the requirements would empower consumers to make informed health care decisions [see Washington Highlights, Nov. 14, 2019].

In its comment letter, the AAMC strongly disagreed that posting negotiated rates will assist patients in making informed decisions about their medical care. Instead of helping patients, the AAMC believes this requirement could lead to widespread confusion and even more consolidation in the commercial health insurance industry. The Association urged CMS not to finalize this proposed rule.

The AAMC agreed that patients should have access to up-to-date cost-sharing information and insurers should be able to inform patients of specific information, such as whether a patient has met their deductible; specific copays, if any; and other requirements such as prior authorization, step therapy, or limits on benefits. But the association argued that this information should be paired with consumer education to ensure that patients are aware that the information they are receiving is an estimate of cost-sharing amounts and that estimates could change based on medically necessary changes in care. 

Many AAMC members have developed tools to assist patients in better understanding their cost-sharing responsibilities. The AAMC encouraged CMS to continue to work with stakeholders as it moves forward to expand price disclosure proposals to build upon current investments to inform patients of their cost-sharing responsibilities.

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