What CMS finalized
On October 5, 2026, HHS (through CMS), the Department of Labor, and the Treasury finalized changes to the 2020 Transparency in Coverage rules. The aim is to publish pricing data people can actually use: smaller files, more context, and fewer gaps. Source: CMS fact sheet.
The Departments named three problems with the 2020 rules: files too large to use, raw numbers with no context and misalignment with the Hospital Price Transparency rule that makes comparison hard. Every change below traces back to one of those.
What changes in the files
The biggest shift: one In-network Rate File per provider network instead of one per plan, with new files that explain the data. CMS expects roughly $174.5 million in annual net savings for plans and issuers starting in year two.
| Area | 2020 rule | Final rule |
|---|---|---|
| In-network Rate File level | One per plan or policy | One per provider network |
| Unlikely provider-rate pairs (e.g., a podiatrist rate for heart surgery) | Included | Excluded, using the plan's or issuer's own taxonomy or claims rules |
| New files | None | Taxonomy File (the mapping used) and Utilization File (providers with at least one paid claim in the latest plan year ending six months before posting) |
| Out-of-network Allowed Amount File | Reported by plan; 20-claim threshold | Aggregated by market type (large group, small group, individual, self-insured); threshold lowered to 11 claims |
| Added context | Limited | Product type (e.g., HMO, PPO) on both files; network name and ID on the In-network Rate File |
| Finding the files | No standard path | A .txt file in the website root with file locations and a monitored contact email, plus a homepage footer link titled "Price Transparency" or "Transparency in Coverage" |
| Update cadence | Monthly | Quarterly for In-network Rate and Out-of-network Allowed Amount Files |
| File format | Any non-proprietary open format | One format; the Departments intend to specify JSON in guidance |
| Accountability | None | Attestation of accuracy and completeness in the In-network, Out-of-network, Taxonomy and Utilization files, plus the name of the CEO, president or designated senior official in those files and the prescription drug file |
What it means for brokers and employers
This is our read of the rule, not CMS's. Price transparency changes the questions your clients will ask and some of them will be uncomfortable. The better your footing on what the files now contain, the better your answers.
The data gets easier to trust. Dropping implausible provider-rate pairs and publishing the taxonomy and utilization context should mean fewer rates that no one would ever be paid.
Out-of-network visibility improves, at the market level. The lower 11-claim threshold and market-type aggregation (including self-insured) should put far more data in these files. Because it is aggregated by market type, expect a benchmark, not your own plan's allowed amounts.
Refresh slows down. Quarterly posting reduces the burden on file users and publishers, as networks and rates do not shift much month to month.
Accountability gets a name. With attestations and a named senior official in the files, plan sponsors have a reason to confirm who posts on their behalf and how that party will attest.
Members get a phone option. Cost-sharing information must also be available by phone on request, which CMS says satisfies the No Surprises Act cost-sharing tool provision, including for grandfathered plans.
Timeline and next steps
Exact dates depend on the Federal Register publication date, which the CMS fact sheet does not give. The rule is on public inspection. Timing is counted from publication:
- The rules take effect 60 days after publication.
- In-network Rate and Out-of-network Allowed Amount File changes apply 5 months after publication.
- Taxonomy, Utilization and text file requirements apply 11 months after publication.
- The self-service tool and phone changes apply to plan years (policy years, in the individual market) beginning on or after January 1, 2027.
Two things worth doing now:
- Confirm who posts your files and who signs the attestation.
- Check how you will answer cost-sharing requests by phone.
The prescription drug file is still under review: the Departments have enforced it case by case since September 2023 and issued a request for information on it on June 2, 2025.
