By Justin Cross, SVP of Employer Solutions, Handl Health
For most of my career on the broker side of this business, I could tell an employer almost everything about their health plan except the one thing that actually determines the year's cost: which provider their employee is going to pick. Many have argued in the past that it is none of their business. But as plan fiduciaries, when members are selecting a $3,000 MRI when a $300 MRI is widely available, shouldn’t we take a pause? Ask an HR leader or a CFO which MRI, which orthopedic surgeon, which hospital their people will choose and the honest answer is always the same. Nobody knows.
Not until the claims come in 60 to 90 days later. Not until renewal, if you're fully insured.
That gap is the reason renewal season feels the way it does for so many of us. We recently hosted a webinar on machine-readable files, the data sets created by healthcare transparency legislation, and it's changing that answer.
Here's what we shared and what I think it means for the HR leaders, CFOs, and brokers heading into another renewal wondering if there's a better way to do this.
Quick answer
Watch the full webinar: See the full discussion on machine-readable files, healthcare pricing data and plan design. Watch on YouTube.
The slow build toward real pricing data
It's easy to forget how recent this all is. Bipartisan legislation opened the door in 2020. Hospital price transparency rules went live in 2021. By 2022, we gained access to genuinely massive data sets, the machine-readable files, or MRFs, that carriers and hospitals are now required to publish for nearly every negotiated rate on nearly every covered service.
In 2023, enforcement started to have real teeth, with penalties for noncompliance. And now, in 2026, we're finally at the point where this data can produce real pricing intelligence. More than just a compliance checkbox, this pricing data is now something employers and brokers can actually use.
It took longer than anyone would have liked. But we're there.
Machine-readable doesn't mean usable
Handl's co-founder and Chief Product Officer, Ria, walked through this in detail during the webinar, and it's worth repeating because it's the part most people underestimate. Publishing a file is not the same as making it usable.
These files are enormous, the early schemas weren't standardized, and a huge share of what's in them — Ria's number was 20 to 30% of what Handl ingests — gets flagged as an outlier before it ever becomes useful. Some of that is what the team calls "ghost rates": numbers technically sitting in a file that don't reflect anything close to a real negotiated rate. A $50 colonoscopy rate isn't a data point. It's a data entry error.
Getting from raw file to something a broker or HR leader can trust takes real rigor, including cross-referencing provider directories, layering in claims data, benchmarking against Medicare at the procedure and carrier level, and assigning confidence tiers to every rate. That's not downplaying the importance of the legislation. It's just the honest state of the data, and it's why "the data is clean out of the box" is a false claim.
What employers can finally see
Back to that question I opened with. In a static plan design, your employees are trusting whatever their doctor's office hands them, and in a static copay or deductible structure, they have no reason to ask about cost. Meanwhile, we've seen contracted rates for the same procedure, in the same market, under the same carrier, range from $15,000 to $24,000 for something like a knee joint replacement. That $9,000 price difference can make a huge impact on total plan costs for a self-funded employer.
With clean MRF data, an employer or broker can now compare their actual claims mix across networks before renewal, not after. They can also compare claims within their selected network and model what would happen if their employees selected higher value providers. In one example we walked through, a fully insured group of about 300 lives in Michigan, roughly $2 million in annual claims, found over 7% in potential savings just by looking at how that claims mix would perform under a more optimal plan design. That's real savings knowable in advance, which is the whole point.
From static copays to dynamic plan design
This is where I think the industry is actually headed, and it's bigger than any one diagnostic tool. Once you can see which providers are meaningfully above market cost and which are performing well on both cost and quality, the old “static copay no matter where you go” stops making sense.
The alternative is a dynamic, or variable, copay: providers in the "green" tier (below market, strong quality scores) carry a lower copay, "yellow" providers sit in the middle, and "red" providers, meaningfully above market rate, carry a higher one.
I've seen plans try the blunt version of this before: a letter telling people a hospital is now out of network. It saves some money and makes a lot of people angry, which usually isn't the point of offering a health plan in the first place.
Dynamic copay design gets at the same goal, steering members toward better value without taking choice away from the employee. They can see the cost before they go, and in a lot of cases, pay less than they do today. The plan, in turn, sees its total cost of care reduced by spending less with high cost “red” tier providers and steering more towards the higher value, lower cost “green” tier.
That's the total cost of care actually coming down, which is a different conversation than the one our industry has been having at renewal for the last twenty years.
Where this goes next
If you're an HR leader or CFO who wants to know your own numbers before your next renewal, we offer a complimentary diagnostic using non-PHI data. Just provide a zip code for your headquarters and that’s enough for us to show you how the networks in your region compare. If you're a broker, the same offer applies for a client you're bringing into a renewal conversation.
None of this replaces the relationship between a broker and their client. It gives that relationship a stronger foundation.
Handl is not a broker, a health plan, or a TPA. We're a group of people who believe employers and their employees deserve to know the actual cost of what they're buying, the same way you'd want to know the cost of anything else before you ordered it.
If you are an HR leader or CFO, ask yourself the question I opened with: do you actually know if your plan is spending money on a $3,000 MRI when a $300 MRI is also widely available? If the honest answer is "not until the claims come in," that's worth a conversation.




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