The Rise of Data Evolution: How the CAA is Redefining Healthcare Decision-Making


In the ever-evolving landscape of healthcare, access to comprehensive data is a game-changer, offering unparalleled insights into utilization and cost. One significant development in this realm is the transition from traditional data access to the groundbreaking Consolidated Appropriations Act (CAA), ushering in a new era of transparency and accountability. 

This is a new frontier. The advent of the CAA, enacted in December 2020, has transformed the way organizations handle health plan fiduciary responsibilities. This legislation not only ensures access to previously restricted data but also imposes penalties for non-compliance, emphasizing the need for a documented “good faith compliance effort” in benefit plans. 

One of the pivotal changes involves the eradication of gag clauses, which previously limited access to vital data. Now, with the appropriate paperwork, employers can delve into the granularity of provider unit cost marking a significant shift in the transparency landscape.  The historical “black box” of provider costs and discounts has been cracked wide open.  Unit cost by provider and payer is no longer “proprietary.”   

Under the CAA, Employers own the responsibility of various key actions to maintain compliance and protect against fines. These include reviewing third-party compensation disclosures, adhering to drug cost reporting requirements, ensuring mental health parity in compensation, and signing an attestation attesting to the removal of gag clauses from medical and pharmaceutical programs. Failure to comply could result in fines of $100 per employee per day, underscoring the importance of a documented process to act on potential savings opportunities. 

Benchmarking is a cornerstone of the health plan fiduciary journey; it is not a mere project but an ongoing process of continuous improvement. It involves shining a flashlight on critical components such as pricing transparency for every service, plan design, mental health parity testing, and the selection of quality vendors. 

In the realm of benchmarking, Health Plan Fiduciary (HPfid) stands out by providing clients with tools and guidance rather than a product. The emphasis is on optimizing spend and fulfilling the fiduciary role, with a focus on repeatable due diligence. To illustrate the process, examples of benchmarking outputs for various service providers could be invaluable. 

Furthermore, collaborations with companies like Innovu can shed light on medical and pharmacy claim costs and plan design benchmarking.  Data driven insights can lead to optimizing network choices or even direct contract opportunities.  


In conclusion, benchmarking in the realm of health plan fiduciary responsibilities is not just a process—it’s a journey towards informed decision-making, transparency, and continuous enhancement of healthcare offerings. The shift from restricted data access to the expansive landscape offered by the CAA brings unprecedented opportunities for organizations to thrive in this dynamic healthcare environment. 

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