I agree with everything you said. We're in the ACA space, so this should been right up our alley (government puts new legislation in with penalties to force employers to do something they don't really want to), but the ACA had a much bigger stick and a much longer runway.
Starting January 2023, insurance companies and plan providers need to publish similar data, so to your point that might be the interdependency required for compliance.
Obligatory these views are my own, not my company's.
Based on what you know about the system and all parties, curious on any ideas you'd have to speed compliance (without bankrupting anyone).
Would increased fines do it? Compliance bonuses [0]? Something else?
[0] Showing a few of my cards, I was really impressed with the inner workings of the FEP program, from a management perspective. They seemed to have landed on an effective system of fine + incentive that strongly encouraged good behavior and positive results.
TBH I didn't dig all that deep. Once you look at the size of the market (~6000 US hospitals, most of them in groups [0]), annual subscription (would need to be some fraction of what they would pay in penalties), percentage of market share you could capture (say 25%), discounts for groups, level of support, investment and unknown source systems, etc., I didn't evaluate it as a viable / likely opportunity, especially outside of our existing market.
All of that said, if you knew the space and backend systems and could figure out a way to make it easy, one thing I did hear is that hospitals don't like to be non-compliant, so I think they want a solution (or this to just go away), it just needs to be a really minimal investment for them in cost and time to implement and maintain. The provider data coming into play in 2023 may be the main driver to "normalize" some of this being out in the open.
Usual disclaimers again: my views, not my company's.
Starting January 2023, insurance companies and plan providers need to publish similar data, so to your point that might be the interdependency required for compliance.
Obligatory these views are my own, not my company's.