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August 24, 2021

On Aug. 20, 2021, the Departments of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) issued frequently asked questions (FAQs) regarding the implementation of the No Surprises Act and transparency provisions of the Consolidated Appropriations Act, 2021 (CAA).
Deferred Enforcement of Some Requirements
The Departments will defer enforcement of the rules regarding:
- Publishing transparency in coverage machine-readable files related to prescription drug pricing (pending further rulemaking);
- Publishing other types of machine-readable files (until July 1, 2022);
- Providing a price comparison tool (until Jan. 1, 2023);
- Providing a good faith estimate of expected charges and Advanced Explanation of Benefits to certain individuals (pending further rulemaking); and
- Reporting of pharmacy benefit and drug costs (pending further rulemaking).