Navigating Transparency Rules: Employer Compliance Resource

In the health benefits context, “Transparency” generally refers to a collection of related but independent rules and requirements from different legal and regulatory sources, intended to increase visibility into healthcare pricing, costs, and plan operations, and to support more informed decision-making at both the plan and individual level. These rules include the Transparency in Coverage Final Rules (TiCFR 2020), Consolidated Appropriations Act of 2021 (CAA 2021), the Consolidated Appropriations Act of 2026 (CAA 2026), and the proposed PBM Fee-Disclosure Rule (2026), although the proposed rule is listed here for reference only and is not addressed in detail below.

The checklist below (available to download or view) provides a practical summary of the key compliance steps employer sponsors should consider for each transparency rule. The matrix that follows provides a more detailed side-by-side overview of each rule’s origin, purpose, requirements, effective date, and employer action items.