Price transparency regulation has been law for years now. What's changed is who it's actually for.
That was the throughline on SIIA's panel, "Navigating the New Era of Health Plan Strategy: Regulation, Data Transparency & Actionable Innovation," moderated by Tracy McGinnis, Chair of SIIA's Price Transparency Committee and founder of DataVoce Consulting.
The panel covered the full arc of where this data comes from, what it takes to make it usable. Lately, my focus is on what employers should actually be doing with it.
The data isn't a black box, even if it still feels like one. It’s not just about expanding regulations, but rather a shift in who's expected to act.
More employers are facing fiduciary duty scrutiny for how they've managed vendor contracts, PBM arrangements and directory accuracy. The center of gravity has shifted to the employer. It's not just disclosure to members, it's employers having the power, and the expectation, to act on the data before it reaches the member at all.
This data isn't meant to be a black box, even though it might still feel like one today. Employers can and should work with their benefits consultants to know exactly what they're legally entitled to, keep an eye on it and use it to manage healthcare spend the way they'd manage any other major line item in the business.
Raw data isn't insight, personalization is
So what does "good" data actually look like once an employer gets access to it?
High-quality actionable data really looks like intelligence at both a plan and member level. It's taking the current MRF pricing data, analyzed and normalized, and blending it with claims data showing how your population actually uses care. That blend is what turns MRF data from a reference point into something personalized.
A key example: a remote tech employer based in a major metro and a manufacturing group in the Midwest are working from completely different utilization patterns. This means completely different strategies, both in plan design and in how they engage members.
Underneath that personalization are three places employers are typically bleeding spend: high-cost providers and hospitals, high-cost claimants and drugs. Reviewing these details shouldn’t be a once-a-year exercise. Employers should monitor their plans throughout the year, because mid-year shifts can still be caught and acted on before they show up at renewal.
Ask the question, insist on access, act on it
Turning these insights into actions is a three-step process for every employer:
- Ask the question. Do you know what an MRF is? Do you know what you're legally entitled to as a plan sponsor? Your carrier or TPA can't restrict your access to your own claims data and call it confidential. That hasn't been true since 2021.
- Be willing to make a change. Employers have historically been kept at arm's length from this data. That's simply not true anymore. Employers are accepting higher rates because they aren’t pushing for plan changes.
- Act on it. Keep working with your broker, but be the one asking for what you need, not a passive recipient of whatever reporting shows up.
Analytics only becomes operational improvement when someone asks the question, insists on the access and builds it into the next plan design cycle.
Collaboration over confrontation
Employers, brokers and carriers should be working together: transparency has to be foundational to any partner relationship, including with consultants. That starts with asking for real data, not the same reporting you've always gotten.
Watch for contracts that quietly limit your own access to your plan or claimant data. And rather than waiting for renewal to find out how a plan performed, set up a proactive, ongoing monitoring rhythm where claims and high-cost claimants are reviewed month over month, not once a year.
Where AI helps
Separate the AI hype from what's genuinely useful. The real value is in answering the "so what" by using AI to surface insights and supercharge the consultant and the employer, not replace either one. Analysis that used to take hours or weeks can now happen in minutes.
One use case I’m excited about is agentic plan monitoring: instead of pulling a report at renewal, continuously watching a plan's claims month over month and flagging the moment something needs a human. This might be a group trending over or under budget, a new high-cost claimant emerging or a member approaching a deductible or out-of-pocket threshold where a nudge could still change the outcome.
The technology you choose matters less than the discipline it enables. AI is what makes 'always watching your data' something an employer can actually do and not just a line on a slide that says they should.
One move to make before your next renewal
The single most important step an employer should take in the next 12 months is to work with your broker to run one plan diagnostic and design simulation before your next renewal. Model a real change such as a different network or a deductible shift so the next decision is made on evidence instead of a guess.
It's a small ask with a large implication: the data employers have spent years fighting to access is only as valuable as the decisions it actually informs.
SIIA's panel discussions are recorded and made available on SIIA.org under the Price Transparency Resource Center.
