The ERISA Industry Committee Recommends Improvements to Advanced Explanation of Benefits and Good Faith Estimate Requirements of the No Surprises Act

WASHINGTON, November 15, 2022 – The ERISA Industry Committee (ERIC) today submitted recommendations to the U.S. Departments of Labor, Health and Human Services, and Treasury regarding the Advanced Explanation of Benefits (AEOB) and Good Faith Estimate (GFE) requirements of the No Surprises Act which would benefit health care plan enrollees and sponsors with better coordination and integration between current tools and systems.

“ERIC member companies provide comprehensive health care and retirement benefits to millions of active and retired workers and their families, and must send out many notices and disclosures that can pose an administrative burden to plan sponsors, overwhelm consumers, and negatively impact the environment,” said ERIC President James Gelfand.  “We strongly urge the Departments to allow electronic delivery of AEOBs and other health plan communications required by law and coordinate the AEOB and Cost-Sharing Liability Tool set forth in the Transparency in Coverage (TiC) Rule to best benefit plan beneficiaries.”

In a letter to the Centers for Medicare & Medicaid Services, ERIC detailed its other key recommendations:

  • Encourage information sharing through application program interfaces and utilizing established interoperability standards.
  • Do not attempt to coordinate AEOB with the Surprise Medical Billing “Informed Consent” and other surprise billing issues, given their complexity and the confusion such an effort would bring to plan participants. 

To read the recommendations regarding AEOB and GFE, visit ERIC’s website here.


All media inquiries to The ERISA Industry Committee should be directed to

About The ERISA Industry Committee
ERIC is a national advocacy organization that exclusively represents large employers that provide health, retirement, paid leave, and other benefits to their nationwide workforces. With member companies that are leaders in every sector of the economy, ERIC advocates on the federal, state, and local levels for policies that promote flexibility and uniformity in the administration of their employee benefit plans.