By Stacey Pogue, Abigail Knapp, and Morgan A. Henderson
In late December 2025, the Departments of Health and Human Services (HHS), Labor, and the Treasury proposed amendments to price transparency requirements adopted in 2020 that apply to health insurers and group health plans. The proposed updates aim to improve access to price data and insights from it. HHS also released a fact sheet and press release with the proposal. Comments on the proposed rule were due by March 2, 2026. The proposed updates would take effect 12 months after the rules are finalized.
Proposed updates to the 2020 health plan price transparency rules, referred to as Transparency in Coverage or TiC rules, stem from an executive order issued in February 2025 that instructs the Departments to “rapidly implement and enforce” existing hospital and health plan price transparency rules adopted during President Donald Trump’s first term. The TiC updates rely on legal authority under the Affordable Care Act and the No Surprises Act.
The 2020 TiC rules envisioned that equipping patients and employers with health care prices would “empower consumers to make informed decisions about their health care, spur competition in health care markets, and slow or potentially reverse the rising cost of health care items and services.” But this vision has not materialized, as the new proposal acknowledges. While health plans are posting an enormous volume of price data, the data are challenging and expensive to access and use. The best-resourced employers are starting to draw insights from the data with considerable effort, but most employers are left in the dark.
More than five years into an era with price transparency requirements on the books, TiC data, along with related price transparency efforts discussed below, are still in a lengthy and iterative implementation phase. At this stage, the focus continues to be on ensuring price disclosures reach consumers, employers, researchers, and other stakeholders, and the jury is still out on whether these efforts, if eventually successful, will spur competition or hold down prices.
Through the proposed rule amendments and related efforts, the Departments are responding to feedback from TiC data users about needed improvements.
In this article, we provide context on the broader array of recent federal price transparency efforts. We then summarize the major changes being proposed in the new TiC amendment and discuss their likely effects.
Background On Related Federal Price Transparency Efforts
As laid out in the proposed amendment, TiC requirements are “one prong in a multipronged approach to prompt greater transparency” of health care prices. Other recent federal price transparency efforts include the Hospital Price Transparency rules adopted in 2019 and statutory requirements enacted in the Consolidated Appropriations Act (CAA) of 2021.
The Hospital Price Transparency rules took effect in January 2021. They require hospitals to post prices for all items and services they offer. HHS has updated hospital price transparency rules three times (in 2022, 2024, and 2026) to improve data access, data quality, and hospital compliance. In response to ongoing issues with hospital compliance and data quality, HHS issued a request for information in 2025, soliciting input on ways to ensure that hospitals post accurate and complete data. HHS has assessed penalties on 27 hospitals to date.
Key price transparency provisions from the CAA of 2021 aim to give consumers cost estimates in advance of their scheduled health care services and help employers access the prices they pay for health care. While advanced cost estimates have been implemented for uninsured patients, those for patients with health insurance (called advanced explanations of benefits) remain unimplemented. In addition, many employers report that, despite statutory protections, they still cannot get complete information on the prices paid for care in the health plans they sponsor.
Background On Transparency In Coverage Data
The 2020 TiC rules require health insurers and group health plans to post price information in a consumer-friendly web tool, meant to help patients see upfront cost-sharing amounts, and in detailed “machine-readable files” (rate files), meant to support researchers, regulators, software developers, and others with the requisite data expertise. Health plans must post three separate rate files each month that contain: in-network negotiated rates for all covered items and services, out-of-network allowed amounts and billed charges for all covered items and services, and negotiated rates and historical net prices for covered prescription drugs. The Departments have not yet implemented the prescription drug rate file requirement from the 2020 TiC rules. The proposed updates do not do so, but the Departments are evaluating whether to implement that requirement through future rulemaking or technical guidance.
Data in TiC rate files are notoriously difficult to access and use for reasons that have been well documented. In the proposal, the Departments identified three primary barriers that stand in the way of TiC goals: the enormous size of TiC files, which makes them inaccessible to many would-be users, lack of contextual information that renders some data ambiguous, and misalignments that limit comparisons across TiC and Hospital Price Transparency data.
What Changes Does The Proposed Amendment Make?
Reducing File Sizes
The proposal would cut redundant and irrelevant data that inflate the size of rate files. The rule would require health plans to prepare one in-network rate file for each provider network, rather than for each plan they offer. This will reduce redundancy, as many different plans use the same network with the same negotiated rates. While the vast majority of TiC file creators already use a table of contents file to help users navigate, this step will help to further standardize and streamline files. The rule requires health plans to identify networks using their “common provider network name,” as there are no uniform network identifiers.
The proposed rule also requires health plans to exclude any “ghost rates,” negotiated rates for a provider who is unlikely to be reimbursed for a service, given that provider’s area of specialty (for example, a psychiatrist’s negotiated rate for a heart procedure). To determine which rates should be excluded from the file, a health plan must apply the internal provider taxonomy it uses to determine whether to deny a claim because a service was not furnished by a provider in an appropriate specialty. Health plans must also submit this information in a new Taxonomy File. The Departments estimate this change will reduce TiC file sizes by 70 percent, but that may be conservative. Recent research found that across 61 insurers, 91.8 percent of all listed rates were ghost rates.
New Data To Provide Additional Context
The proposed rule includes a number of significant requirements to add contextual information to the files. Insurers will be required to provide a Change-log File for each in-network rate file, which identifies any changes made from the previous iteration. This update will help stakeholders use these files more efficiently, as well as potentially facilitate new understandings of negotiated rate changes over time.
The proposal would also require a Utilization File that lists all covered items and services that were reimbursed over a 12-month period and each in-network provider that was reimbursed. In other words, the Utilization File would indicate whether provider A furnished service X over the covered time frame. While ghost rates will already be removed from in-network files, thus mitigating the direct utility of the Utilization File in the TiC data, this could be a rich data source that could be used for a number of ancillary analyses (including, but not limited to, network adequacy and analysis of provider specialization patterns). However, we note that the Utilization File would not specify the volume of services provided, only the providers delivering the services.
The proposed rule also requires additional data elements, including a numerical enrollment total for each plan in the in-network rate file and the product type (for example, preferred provider organization or health maintenance organization) associated with each coverage option.
The proposed rule also takes several steps to increase the amount of price data disclosed in the out-of-network price files. The Departments explain that many health plans post out-of-network rate files with limited or no price data, largely because the current rule directs plans to omit prices for any out-of-network provider associated with fewer than 20 claims for a specific service. The proposal would reduce that threshold from 20 to 11 claims per service and double the reporting period, from a 90-day period before the rate file is published, to a six-month period. Finally, the proposal would require health plans to aggregate out-of-network price data at the market level (individual, small group, large group, and self-insured markets), which will minimize privacy concerns associated with reducing the claims threshold.
Improving Access
TiC rate files can be hard to locate on health plans’ websites. The proposal would create a new Text File that serves as a consistent digital pathway for users and automated “webcrawlers” to find rate files across various websites, aligning with a similar provision in the 2023 hospital price transparency rule. The Text File must also include contact information for a point person who can address questions about the rate files. The proposal would also require health plans to provide cost sharing and price information to consumers via phone, adding to requirements that such information be available via a web tool and, if requested, in a paper format.
Frequency Of File Updates
The proposal reduces the frequency of in-network and out-of-network rate file updates from monthly to quarterly. The Departments do not expect this change to meaningfully diminish data quality because contracted rates are generally locked in for a year or longer. They do, however, expect this change to reduce costs associated with storing and accessing the files.
Will The Changes Have A Meaningful Impact On Data Users?
On balance, the proposed changes will significantly facilitate the use of these files. TiC machine-readable files will be easier to locate, with a more streamlined file structure, with significantly fewer ghost rates, and additional ancillary information (for example, the Change Log) that will facilitate analysis. The out-of-network file should become more populated, and the Utilization File will allow for additional, related analyses.
While large, third-party data vendors have been able to deal with the existing challenges to TiC data, these challenges drive up the costs of collecting and synthesizing the data, which increase costs to end users. These proposed updates should reduce barriers to entry in the secondary market for data collection and processing, and result in wider access to price transparency data.
Additionally, despite the stated goal of aligning TiC and hospital price transparency data, it is not clear whether the proposed rule would achieve this. Recent research shows that direct comparisons of hospital and TiC data reveal very little overlap. We encourage commenters to push for clarity on this point.
Looking Ahead
Changes in the proposed rule will make TiC rate files easier to find and use, likely making price data, and insights from them, more widely available. Yet, even if complex price transparency data become easier to use, it is not clear whether they will lead to meaningful reductions in commercial health care prices. Providers and private equity firms may leverage the data to maximize revenue, pushing up costs, while insurers may have limited incentive to aggressively negotiate for lower prices.
Regardless, the proposed amendment takes a necessary step forward. Prices posted in TiC rate files today are not “transparent.” Rather, they are often inaccessible to all but the best-resourced stakeholders. The 2020 TiC rules envisioned that researchers, policy makers, state and federal regulators, and employers would leverage the data to help consumers by delivering “more targeted oversight, better regulations, market reforms to ensure healthy competition, improved benefit designs, and more consumer-friendly price negotiations.” In other words, price transparency should inform individual consumers, as well as the complementary policy approaches that hold greater potential to lower health care prices. TiC data, for example, may prove valuable to regulators evaluating proposed health care mergers and monitoring completed ones, or large employers pursuing direct contracting. These data-driven strategies need good data as a starting point, and this proposal moves in that direction.
Authors’ Note
Stacey Pogue and Abigail Knapp are employees of the Center on Health Insurance Reforms at Georgetown University’s McCourt School of Public Policy. Morgan Henderson is an employee of The Hilltop Institute at the University of Maryland, Baltimore County. The research related to this article was funded by Arnold Ventures.
Stacey Pogue, Abigail Knapp, and Morgan A. Henderson “Taking Stock Of Proposed Updates To Health Plan Price Transparency Rules” March 17, 2026, https://www.healthaffairs.org/content/forefront/taking-stock-proposed-updates-health-plan-price-transparency-rules. Copyright © 2026 Health Affairs by Project HOPE – The People-to-People Health Foundation, Inc.
