In May, the Trump administration issued guidance and requests for information (RFIs) to enhance healthcare price transparency, focusing on both hospitals and health plans. For hospitals, the guidance reiterates the need to provide actual dollar amounts for payer-specific negotiated charges in machine-readable files (MRFs) rather than percentages, and it seeks input on improving the accuracy and completeness of MRF data. For health plans, the RFI addresses concerns about file size and data integrity, and it explores the implementation of net prices for covered prescription drugs, indicating that the administration plans to issue revised schemas and may pursue further transparency rulemaking.
One Big Beautiful Bill Act Has Compensation & Benefits Impacts for Nonprofit Health Systems
The US House of Representatives passed its One Big Beautiful Bill Act on May 22, 2025 (the Act), but nonprofit health systems may not find much about the Act that’s attractive. If passed by the US Senate and signed into law, the Act would threaten already thin operating margins at nonprofit hospitals and health systems by expanding the executive compensation excise tax, taxing parking, and similar employee benefits.
An Update on NAIC’s Consideration of AI Model Law for Insurers
The National Association of Insurance Commissioners’ (NAIC) Big Data and Artificial Intelligence (H) Working Group released a request for information (RFI) to explore the potential drafting of a model law to regulate insurers’ use of artificial intelligence (AI) systems. The RFI asks stakeholders to provide comments on whether uniform statutory requirements for AI are needed in the insurance industry.
“Big, Beautiful Bill”: Federal Tax Bill Would Restrict the Employee Retention Credit
A new federal tax bill under consideration in the US House of Representatives proposes major changes to the Employee Retention Credit (ERC), including disallowing claims made after January 31, 2024 – even if they were filed before the official deadlines in April 2024 and 2025. It would also extend the Internal Revenue Service’s statute of limitations for assessing ERC-related amounts to six years, raising uncertainty for taxpayers with pending or previously approved claims.
Enforcement of Mental Health Parity Regulations Suspended: Takeaways for Plan Sponsors and Health Insurance Issuers
Enforcement of the 2024 final regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA) has been suspended due to litigation by The ERISA Industry Committee. In response, the US Departments of Labor, Health and Human Services, and Treasury announced that they will not enforce the new rule until the case is resolved, plus an additional 18 months.
The suspension provides temporary relief from several burdensome requirements in the 2024 Final Rule, such as the “relevant data requirements” (which generally required parity in outcomes), the controversial “meaningful benefit” test, and fiduciary certification mandates. However, plan sponsors must still comply with MHPAEA’s core obligations and the requirements of the Consolidated Appropriations Act, 2021, including the written nonquantitative treatment limitation comparative analysis.
