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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

Among the many Executive Orders issued by President Donald Trump’s administration, <a href="https://www.federalregister.gov/documents/2025/02/28/2025-03440/making-america-healthy-again-by-empowering-patients-with-clear-accurate-and-actionable-healthcare" target="_blank" rel="noreferrer noopener">Executive Order 14221</a> (the “Order”) reinforces and expands healthcare price transparency enforcement. This Order builds on Executive Order 13877, issued in 2019, which first established federal price transparency rules requiring hospitals and health plans to disclose pricing information to consumers. These rules aimed to empower consumers, but enforcement has been inconsistent. While the new Order does not change any existing laws or regulations, it signals a renewed commitment to oversight and compliance. Group health plan sponsors should evaluate their compliance strategies to prepare for heightened enforcement.

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How We Got Here: A Look at Executive Order 13877 issued in 2019

Executive Order 13877, issued in 2019 during Trump’s first term, led to finalized transparency regulations in 2020, which require, among other things, most group health plans to:

Provide user-friendly tools allowing consumers to check pricing for common medical services (e.g., negotiated in-network rates, out-of-network allowed amounts, estimates for certain covered services or items).

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Publicly post machine-readable files showing negotiated in-network rates, historical payments to out-of-network providers, and prescription drug information).

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Despite these mandates, compliance has been uneven, and enforcement efforts have lagged. The Order aims to correct this by requiring stricter oversight and ensuring that consumers have meaningful access to healthcare pricing data.

Key Provisions of Executive Order 14221

The Order directs the Departments of the Treasury, Labor, and Health and Human Services to enhance enforcement of healthcare price transparency regulations. Within 90 days, these agencies must:

Require disclosure of actual prices for healthcare services and prescription drugs, rather than estimates.

Ensure pricing information is standardized and easily comparable across hospitals and insurers.

Implement stronger enforcement policies to hold noncompliant entities accountable.

What This Means for Group Health Plans

With federal agencies now under orders to ramp up enforcement, group health plan sponsors must take proactive steps to assess and strengthen their compliance efforts. Group health plan sponsors that have not yet published their plans’ required pricing data – or whose disclosures are incomplete – should prioritize corrective action to avoid potential penalties. This includes conducting internal audits, coordinating with insurers or third-party administrators and consulting legal counsel to ensure full adherence to the latest regulatory requirements.

For more details on the Order and what it means for your group health plan, please reach out to Stephanie Grant, De’Andre Robbins or a member of Warner’s Employee Benefits Practice Group.

Senior Counsel

Stephanie H. Grant

Associate

De’Andre L. Robbins

Employee Benefits

Executive Order Directs Enhanced Enforcement of Group Health Plan Transparency Rules

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Executive Order Directs Enhanced Enforcement of Group Health Plan Transparency Rules

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