In February 2026, the Center responded to a proposed rule from the Department of Health and Human Services (HHS), Department of the Treasury, and Department of Labor (the Departments) to update Transparency in Coverage (TiC) data reporting requirements. The proposed changes are intended to make the TiC machine-readable files (MRFs) more usable by reducing file size and number, improving context, and increasing standardization. 

The TiC rule, which took effect in 2022, requires commercial health plans to disclose the rates they negotiate with every healthcare provider, including all hospitals, physician groups, labs, and ambulatory surgery centers. Until TiC data were released, employers lacked a reliable, neutral “source of truth” to compare prices and therefore know whether the prices they are paying for coverage are fair. TiC data is emerging as an essential tool for employers to understand their market positioning and negotiated rates relative to others, enabling smarter purchasing and lower healthcare costs for employees. As employers increasingly engage with TiC files, it has become clear that improvements are needed to make price transparency data more meaningful and actionable for employers.

Drawing on our work to equip employers with data to inform purchasing decisions, the Center offered recommendations to enhance TiC data quality and reliability, expand the utility of the TiC files, and strengthen compliance. Specifically, the Center recommended that the Departments should:  

• Enhance TiC data quality and reliability: We supported the Departments’ efforts to improve data usability through proposals to promote data simplification, reduce file size, provide plain language instructions, promote better alignment with the Hospital price transparency reporting requirements, and require reporting of important contextual information alongside rates. While we appreciate the Departments’ intent to address the “ghost rate” issue, which refers to rates for items and services a clinician is highly unlikely to perform, we offer an alternative, more precise method for consideration that will not add undue burden to those group health plans and issuers subject to these rules. A recently published paper from Center grantee Simple Healthcare describes how the Departments’ proposal may compromise data quality and how a hybrid approach would result in more precise and accurate “ghost rate removal.”
• Expand the utility of the TiC files: Inclusion of new data elements would enable employers to generate more comprehensive and actionable insights on behalf of their employees and to fulfill their fiduciary responsibilities. We believe many of the Departments’ proposals advance this goal, including the proposals to connect rate information with new data on product types (i.e., Health Maintenance Organization (HMO) or Preferred Provider Organization (PPO)), provider networks, plan enrollment totals, and to increase the amount of usable data in the Out-of-Network Allowed Amount Files. We recommended the Departments require reporting of quantities data (i.e., claims volumes), which, if reported, would enable the creation of data insights for employers as plan sponsors beyond addressing the “ghost rate” issue.
• Strengthen compliance: Widespread noncompliance with TiC file construction and completeness severely limits the data’s utility. A major thrust of this proposed rule is aimed at making the data cleaner, which should reduce the reporting burden on file submitters and will allow users and policymakers to parse data compilation errors from deliberate omissions. Given these important advancements, it is prudent that the Departments go further in the final rule and put forth novel enforcement provisions. We pointed the Departments to new compliance and enforcement models under development in states like Colorado and Indiana as promising examples to emulate at the federal level.