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Letter to HHS on Proposed Transparency Reporting Rule

Policy Integrity submitted a letter today to the Department of Health and Human Services on its upcoming Transparency Reporting rule, mandated by the Affordable Care Act of 2010. The rule would develop uniform disclosure standards for group health plans and health insurance issuers, requiring them to provide consumers with new, more detailed information on likely co-pays for particular plans or treatments; providers would also have to provide consumers with a document that summarizes benefits and explains coverage clearly in four pages or less.

To maximize benefits to insurance shoppers, HHS should establish a clear and easily comprehensible disclosure format free of overly technical language and extraneous information. This will help insure that readers do not skip over important information.

HHS should also tailor its rule for consumers, using cues to steer people away from bad decisions. For example, HHS could require that common medical problems be presented up front with statistics on their occurrence depending on age and other risk factors to compensate for the fact that individuals tend to underestimate risks to their lives and health.

Additional benefits of the proposed rule include making it possible for regulators to use the disclosure information to facilitate industry monitoring, and creating a more robust market in which plans and providers could be forced to compete on both price and quality once more informed consumers are able to judge policies on both rubrics.