Putting TiC to Work: Insights from a Discussion of Transparency in Coverage Data
Last Updated June 27, 2025
At AcademyHealth’s 2025 Annual Research Meeting, the Peterson Center on Healthcare brought together researchers to examine opportunities and challenges presented by Transparency in Coverage (TiC) data—an unprecedented source of information about commercial market healthcare prices.
The panel, moderated by the Center’s Associate Director of Programs, David Schleifer, represented a range of experiences working with TiC data:
- Alex Bohl, senior client partner at Mathematica
- Alison Evans Cuellar, professor of health administration and policy at George Mason University
- Yuvraj Pathak, vice president of strategy and research at Simple Healthcare
- Kosali Simon, professor of health economics at Indiana University
Very Big Data
Since 2022, federal regulations have required insurers to publish machine-readable files containing negotiated prices and out-of-network paid amounts. Pathak and Simon described the barriers to working with this data, including file sizes that can exceed 600GB per insurer and the files’ JSON format. Pathak and his colleagues at Simple Healthcare have also estimated that 96.5% of the data consists of “ghost codes,” procedure codes for providers who do not offer those services.
Despite these difficulties, Cuellar noted that the release of TiC data democratizes access to commercial market price information that was previously considered proprietary. Bohl noted that vendors including Mathematica now assemble and clean TiC data so that researchers can more easily access and analyze it. At a related panel during the AcademyHealth meeting, Jean Abraham discussed a project at the University of Minnesota that will make TiC data for many of the country’s largest health plans more easily available to researchers and policymakers.

TiC in Action
Panelists described how they are using TiC data to understand healthcare pricing and inform purchasing and policy. For example,
- Geographic price variation: Simon and colleagues have used TiC data to reveal substantial pricing variation at the county level in the commercial market.
- Market competition: Pathak and colleagues have used the data to study relationships between commercial prices and hospital market share.
- Commercial price negotiation: Bohl described how researchers have used Mathematica’s TiC files to support employer price negotiations and provider rate negotiations, and to understand how market consolidation and Medicare and Medicaid rates affect provider reimbursement.
- Public payer benchmarking: Cuellar explained that few states understand how their Medicaid rates compare to commercial rates. Her ongoing work with colleagues including Lauryn Walker from the Virginia Center for Health Innovation uses TiC data to help the state of Virginia understand commercial rates and guide Medicaid rate setting.
Audience members raised other opportunities for using TiC data, such as determining whether regions with low Medicaid reimbursement rates tend to have higher commercial rates or supporting patients who are seeking information about the costs of their care.
Room for Improvement
Our conversation ended with panelists suggesting ways to improve TiC data, including:
- Reducing the volume of the data, such as by removing duplicative and redundant data elements related to sites of service
- Clarifying provider networks and identification beyond tax identification numbers
- Filtering out obvious ghost codes
The panelists’ recommendations aligned with remarks during another panel at the conference from Ellen Montz, former Deputy Administrator and Director at the Center for Consumer Information and Insurance Oversight and now a managing director at Manatt. She led the initial implementation of the TiC rules and noted that the Departments of Health and Human Services, Labor, and Treasury recently released a new TiC file schema designed to streamline the data. Ellen explained that the departments will collect feedback on the new TiC file schema via GitHub and in webinars. She added that the departments also issued an RFI requesting input regarding how to add prescription drug price information to the TiC data. She encouraged data users and other stakeholders to provide input in order to help TiC data realize its full potential.
Despite its complexities, TiC data enables novel and powerful insights into commercial market prices. The new file schema may make TiC data even more valuable, supporting purchasers and policymakers in making better healthcare spending decisions.
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