The Department of Health and Human Services (HHS), Centers for Medicare & Medicaid Services (CMS), and Departments of Labor and the Treasury, finalized updates to the federal Transparency in Coverage (TiC) rules. The updates affect machine-readable file reporting, data accuracy requirements and participant access to cost-sharing information. Although carriers and third-party administrators (TPAs) typically handle much of the technical reporting, employers should confirm responsibilities are being met.
Notable changes include:
- Expanded access to cost-sharing information - Since 2023, health plans and insurers have been required to provide participants with an online self-service cost-comparison tool and paper disclosures upon request. For plan years beginning on or after January 1, 2027, plans must also provide applicable cost-sharing information by telephone upon request.
- Standardized pricing information - CMS is updating reporting requirements to improve the usefulness and consistency of publicly available pricing data and reduce the size of MRFs.
- Quarterly machine-readable file (MRF) reporting - Beginning March 6, 2027, in-network negotiated rates and out-of-network allowed amounts files must be updated quarterly rather than monthly.
- New data accuracy requirements - Beginning March 6, 2027, applicable MRFs must include an attestation confirming that the information is complete, accurate and compliant to the best of the plan's or issuer's knowledge and belief. Employers should confirm whether their carrier or TPA will assume these responsibilities through a written agreement.
Healthcare price transparency remains an important component of employer-sponsored health plan compliance. As federal requirements evolve, employers should understand their responsibilities and work with service providers to maintain compliance. Contact your Bukaty benefits team with questions about how these changes may affect your health plan.