Summary of the Transparency in Coverage (TiC) Rule and No Surprises Act under the Consolidated Appropriations Act, 2021 (CAA)


  1. Provider network termination notices to members for Continuity of Care on 1/1/2022
      •  PHP is generating termination files 3 x weekly for our payers to notify members who are in continuous care
      • Payers can obtain the Network allowed amounts for a terminated provider’s claim from our portal
  2. Provider data accuracy on 1/1/2022
      • PHP is updating our provider data 3 x weekly and performing an audit every 90 days
  3. Payer Contracting
      • References to “GAG clauses” have been removed from all agreements on 1/1/2022
  4. Qualified Payment Amounts (QPA) on 1/1/2022
      • PHP can provide a Qualified Allowed Amount (QAA) for services in support of the QPA requirement, however, our QAA is based on data from our 48 counties only
  5. Machine-readable files (MRF) must be generated and made available on a public website no later than 7/1/2022 for:
      • In-network rates for covered items and services
      • Out-of-network allowed amounts and billed charges for covered items and services
          • This would fall under the responsibility of the Payer due to the additional benefit calculation requirements
      • Currently the requirement for MRF Pharmacy data has been deferred
  6. Price-comparison tool and cost-estimating tool (first 500 services) effective 1/1/2023
      • PHP does not have the health plan benefit information. We are working on an ‘Allowed amount” price-comparison tool