What comes next for price transparency rules?

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In December 2025, HHS, alongside the Labor and Treasury departments, proposed significant updates to healthcare price transparency rules. 

Comments for the proposed updates were due by March 2, 2026, and the proposals will take effect 12 months after the rules are finalized. 

In a March 30 article, faculty at Washington, D.C.-based Georgetown University outlined each component of the Transparency in Coverage rules and what they will mean for healthcare organizations. 

Here are seven things to know about the new TiC rules: 

1. The proposed amendments to the TiC rules stem from a February 2025 executive order directing agencies to “rapidly implement and enforce” price transparency rules first adopted during Trump’s first term. 

2. The departments identified three primary barriers standing in the way of TiC’s goals: the sheer size of the machine-readable files, which makes them inaccessible to most users; a lack of contextual information that renders some data ambiguous or uninterpretable; and misalignments between TiC and hospital price transparency data that prevent useful cross-comparisons. The proposed amendments are designed to address all three.

3. One of the most notable findings in the proposal: recent research found that across 61 insurers, 91.8% of all rates listed in TiC files were “ghost rates” — negotiated rates for providers who would be unlikely to ever be reimbursed for that service (think a psychiatrist’s listed rate for a heart procedure). The proposed rule would require health plans to strip these irrelevant rates from their files, using the same internal provider taxonomy they already use to deny out-of-scope claims. The departments estimate this change alone will reduce TiC file sizes by 70%—which may be a conservative estimate.

4. Beyond trimming the existing files, the proposal adds new required data outputs. A Change-log File would track what changed from one file version to the next, helping analysts identify rate shifts over time. A Utilization File would list all covered items and services that were actually reimbursed over a 12-month period, along with which providers delivered them — useful for network adequacy analysis and studying provider specialization patterns, though notably it won’t include service volume. A Taxonomy File would document the specialty classifications health plans use to determine appropriate providers. And a plain-text Index File would serve as a consistent digital directory to help users — and automated web crawlers — locate a plan’s rate files and reach a designated contact person with questions.

5. Currently, many health plans post out-of-network rate files with little to no usable price data, largely because the rules allow them to omit prices when fewer than 20 claims exist for a given provider-service combination. The proposal would lower that threshold to 11 claims, double the reporting window from 90 days to six months, and require plans to aggregate out-of-network data by market segment (individual, small group, large group, self-insured). 

6. The proposal would reduce the required update frequency for in-network and out-of-network rate files from monthly to quarterly. The departments argue this won’t meaningfully reduce data quality — contracted rates are generally locked in for a year or more — while it will reduce the significant storage and access costs associated with the current cadence. On the consumer-facing side, plans would also be required to provide cost-sharing information by phone upon request, adding to existing requirements for online and paper access.

7. The authors of the analysis are cautiously optimistic: these changes will make TiC files easier to find, use, and analyze, and should lower barriers to entry for smaller data vendors and researchers. But they cautioned that even if the data becomes more accessible, it’s not guaranteed to drive prices down. Providers and private equity firms may use the same data to maximize revenue, while insurers may have limited incentive to negotiate aggressively on behalf of plan sponsors.

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