Timeline on consumer tool for Transparency in Coverage Rule and the impact of the No Surprises Act

So, there are a lot of people that are thinking that the Transparency in Coverage Rule for the consumer really doesn't take effect until January 1st, 2023, whereas there are compliance requirements for the employer that occur a year prior to that on January 1st, 2022. But the consumer tool actually has become a requirement of the No Surprises Act, which is a separate law that was enacted in December of 2020. And that calls for some very similar functionalities in terms of the consumer self-service tool, or the ability to shop, the ability to see what the consumer's out-of-pocket exposure is going to be ahead of becoming obliged to pay for something or before getting services. There's a lot of provisions in there, but ultimately it really suggests that On January 1st, 2022, employers should plan to have a self-service, consumer-friendly ability to shop on mobile phones and web applications.