OON Allowed Amount file for plans with 0 claims

[kdai-KP]

What is the expectation for producing "empty" OON allowed amount files for plans with 0 claims within the reference lookback period?

The current Github schema states that OON allowed amount MRFs are not required for plans with fewer than 20 claims. However, in a later technical clarification update, it's stated that an empty MRF should still be produced for plans that do not meet the threshold.

How is your organization handling the production (or exclusion) of plans with 0 claims to reference?

From Github:

The allowed_amount is each unique allowed amount, reflected as a dollar amount, that a plan or issuer paid for a covered item or service furnished by an out-of-network provider during the 90-day time period that begins 180 days prior to the publication date of the machine-readable file. To protect patient privacy, a plan or issuer must not provide out-of-network allowed amount data for a particular provider and a particular item or service when compliance would require the plan or issuer to report out-of-network allowed amounts paid to a particular provider in connection with fewer than 20 different claims for payment. Issuers, service providers, or other parties with which the plan or issuer has contracted may aggregate out-of-network allowed amounts for more than one plan or insurance policy or contract. If information is aggregated, the 20 minimum claims threshold applies at the plan or issuer level.

From Technical Clarification site - question #15:

Question #15: If a plan does not meet the 20-claim threshold for any of its allowed amounts, must a file be produced?
Answer #15: While a plan or issuer with fewer than 20 claims for any of its allowed amounts is not required to report payment of OON allowed amounts, the file must still be produced. Please refer to 45 C.F.R. § 147.212(b)(1)(ii)(C). An example of what that would look like is here. The information in the allowed amounts file will be minimal due to the lack of information to report. However, the file needs to be created so that consumers of the file know that the plan does not have any claims that meet the 20- claim threshold. If plans continue to not meet this threshold, the maintenance of these files will be minimal.