Industry Watch Alert
The rule refines the existing transparency framework by focusing on usability through simplified files and harmonized consumer disclosures. Organizations have until February 21, 2026 to comment on operational and technical details that could shape the final requirements.
Executive Summary
- CMS, the Departments of Labor and Treasury, and HHS jointly issued a proposed rule to revise the 2020 Transparency in Coverage requirements.
- The proposal reorganizes machine-readable files, adds change-log and utilization files, and shifts reporting from monthly to quarterly.
- Out-of-network price reporting would expand while consumer cost-sharing tools would align with No Surprises Act protections.
- The public comment period closes February 21 2026.
- Agencies describe the updates as essential to making pricing data clearer, smaller, and more actionable for consumers, employers, and researchers.
The Impact
1. Data architecture and vendor coordination
Reorganizing in-network files by provider network and introducing change-log files will require revised ingestion, validation, and audit protocols across analytics vendors and delegated entities.
2. Reporting cadence and resource allocation
Quarterly submissions reduce volume but increase the importance of version control and timely correction, affecting staffing models and SLAs.
3. Expanded out-of-network analytics
Lower claims thresholds and longer look-back periods enlarge the dataset, prompting updates to extraction logic and de-identification safeguards.
4. Alignment with No Surprises Act disclosures
Consistent cost-sharing details across web, print, and phone channels will necessitate updates to consumer tools, contact-center scripts, and print fulfillment workflows.
5. Future prescription-drug transparency
The proposal defers major prescription-drug file changes, signaling a separate forthcoming rule and the need for adaptable data-generation systems.
Sources
Federal Register. Public Inspection Document – Transparency in Coverage Proposed Rule (CMS-9882-P)
Centers for Medicare & Medicaid Services. Trump Administration Proposes Significant Updates to Disclosure Requirements to Make Health Care Prices Clear, Accurate, and Actionable for Americans
—. Fact Sheet: Transparency in Coverage Final Rule Fact Sheet (CMS-9915-F)
—. Medical bill rights: No Surprises Act
FAQ
What changes does the Transparency in Coverage proposed rule make to in-network rate files?
The rule would exclude rarely performed services, reorganize data by provider network, add change-log and utilization files, and shift submissions to a quarterly schedule.
How often would health plans submit machine-readable files if the rule is finalized?
Plans and issuers would submit in-network rate and allowed-amount files on a quarterly basis instead of monthly.
When is the deadline for public comments on the proposed updates?
Written comments must be submitted by February 21, 2026.
How does the proposal expand disclosure of out-of-network prices?
Allowed-amount files would be organized by insurance market type, use a lower minimum of 11 claims, and cover six months of data with a nine-month look-back.
Which consumer-facing tools must align with No Surprises Act protections under the proposal?
Online, telephone, and print cost-sharing tools provided by plans must present identical, up-to-date information including balance-billing notices.
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