The Departments of Labor, Health and Human Services, and Treasury published a final rule updating the “Transparency in Coverage (TiC)” regulations, which require health plans and insurers to publicly disclose negotiated rates and pricing information through machine-readable files (MRFs).
For CHROs and HR leaders overseeing self-insured health plans, this update has important implications. It changes how organizations disclose pricing data—and, in principle, makes that data far more usable for benchmarking vendor performance, negotiating rates, and fulfilling fiduciary duties.
Why the Update Was Needed
-
The original TiC rule (finalized during the first Trump Administration) required plans and issuers to publish negotiated rates and out-of-network allowed amounts in machine-readable files.
-
In practice, these files became so massive and technically complex that employers, researchers, and innovators struggled to extract meaningful insights from them.
This final rule is designed to fix that, in line with Executive Order 14221 on empowering patients with clear, accurate, and actionable health care pricing information.
Key Changes Self-Insured Employers Should Know
-
New contextual files and data elements simplify the link between networks and rates. The rule adds new data elements to the “In-Network Rate” and “Allowed Amount” files, including product type (e.g., HMO, PPO), provider network name, and a new provider network identifier. This change reduces ambiguity and makes it easier to identify which network a given rate applies to.
-
Reporting level and aggregation changes cut down on irrelevant data. The rule changes how rates are grouped and reported, eliminating in-network rates for unlikely provider-service combinations. The aim is to cut down on noise and reduce irrelevant data, so the files are easier to use.
-
Lower claims threshold expands availability of out-of-network data. The rule lowers the minimum claims threshold for reporting allowed amounts from 20 to 11 claims per item or service, making more historical pricing data available while maintaining CMS privacy protections.
-
Reporting frequency reduced to quarterly. Plans and issuers will move from a monthly to a quarterly reporting cadence for the “In-Network Rate” and “Allowed Amount” files to ease the compliance burden and keep data reasonably current.
-
Improved findability. A new Text File (contact information for the files) and a required footer with website URLs make it easier for file users to locate the machine-readable files.
-
Phone-based price comparison guidance. Plans and issuers must now make cost-sharing and price comparison information available by phone, in addition to the existing online tool and paper-upon-request options. Compliance with this requirement also satisfies the separate price comparison guidance requirement under Section 114 of the No Surprises Act. This extends to grandfathered plans that are otherwise exempt from the TiC rules.
What This Means for Your Team
For CHROs (or any named fiduciary) overseeing self-insured health plans, now is the time to coordinate with your benefits and legal team, third-party administrators (TPAs) and vendors to ensure compliance with the new requirements, including:
-
Confirming how your current MRF vendor plans handle the new data elements (network ID, product type) and the lower claims threshold.
-
Updating internal processes for the shift to quarterly (rather than monthly) reporting.
-
Making sure your plan’s phone-based price comparison capability is in place.
