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Since 2022, the Transparency in Coverage (TiC) rules have required health plans to publish the prices they negotiate with providers. But the files have been enormous and cluttered with duplicate rates, ambiguous terms, and prices for services no provider would ever bill. The data was public, but making it usable took serious cleanup work.
A final rule published October 6 by HHS, Labor, and the Treasury aims to fix that, with smaller files, clearer context, and more accountability. The new TiC rule, which cites Serif Health as a source in multiple key sections, is an important next step for the industry. This blog focuses on what’s new and why it matters.
Files organized the way the market works
Today, plans report negotiated rates plan by plan, even though dozens of plans often share the same network and the same contracted rates. The result is massive duplication. Under the new rule, plans will publish one in-network rate file per provider network, labeled with a common network name and ID. Each plan using that network is listed with its HIOS ID or EIN and product type, such as HMO or PPO.
It sounds like a technical tweak, but this may be the most consequential change in the rule. Consistent identifiers make it far easier to map rates across plans and clearly identify which plans are on which network. This change also makes it easier to answer the questions buyers actually ask: Which networks include this health system? How does this PPO's rate compare with that HMO's? It also aligns payer files more closely with hospital price data.
Cutting the noise
Anyone who has worked with TiC data knows the “ghost rate” problem too well: a negotiated price for heart surgery attached to a dermatologist, simply because a contract's fee schedule covers every code. These phantom rates bloat files and distort analysis, as we’ve written about before and was cited in the new final rule. The final rule requires plans to remove rates for providers who are unlikely to be paid for a service given their specialty.
To keep that process transparent, two new supporting files arrive. A taxonomy file shows how each plan maps billing codes to provider specialties, refreshed quarterly and a utilization file flags which in-network providers were actually paid for which services. It's a simple yes or no rather than claim counts, but it lets users separate rates for care that's delivered from rates that exist only on paper.
The goal is that smaller, far more useful files should follow.
A clearer view of out-of-network costs
Out-of-network allowed amounts have been the thinnest part of TiC. In our experience, a 20-claim minimum meant many plans reported little or nothing. The new rule lowers the threshold to 11 claims, which was a recommendation from our team back in October 2023. The rule also extends the reporting period from 90 days to six months, and lengthens the lookback from 180 days to nine months. Data will also be reported by market (individual, small group, large group, and self-insured) rather than by plan.
Since the OON allowed amounts provided very few usable insights until now, these changes may move the needle on the much-needed ability to analyze and compare these costs to make better decisions. It also may prove interesting and helpful for ongoing IDR-related issues.
Easier to find, harder to ignore
The rule also tackles access and accuracy. The changes include:
- Plans must add a “Price Transparency” or “Transparency in Coverage” links to their website footer and post a text file in their site's root folder listing file URLs and a monitored contact email.
- Files must be reachable by any person, script, or web crawler, with no logins or blocking.
- Each file must carry an attestation naming the CEO or another senior official responsible for it, and the agencies intend to name JSON as the single required format.
For data users, that means less time hunting for files and more confidence in what's in them.
Consumers may benefit too. For plan years beginning on or after January 1, 2027, plans must provide cost-sharing estimates by phone, using the number on the member ID card, in addition to online and paper options.
The trade-offs and open questions
To ease the burden on plans, the main files move from monthly to quarterly updates. The agencies also dropped two proposed elements: enrollment totals in the in-network files and a change-log file that would have flagged rate changes between postings. The technical details for Schema 3.0 are also still to come.
Progress on prescription drug price transparency (finally!)
While the new rule still doesn’t enforce the prescription drug file, the agencies plan to begin implementing it “in short order,” and are committed to a timeline of beginning to develop the schema for the prescription drug file in November 2026 and to finalizing enforcement for November or December 2027. This piece, which was strongly emphasized in the news conference, is very exciting progress in the price transparency data story that has remained opaque for too long.
Key dates to know
- March 6, 2027: Changes to existing in-network and out-of-network files take effect, with the first quarterly files due April 1, 2027.
- September 6, 2027: The taxonomy file, text file, and footer link are required, with first postings due October 1, 2027.
- July 1, 2028: The first utilization file is due, then annually.
Why this matters
The first TiC rules opened the books. This rule makes them readable. Cleaner, network-level files mean employers can more easily spot when one provider charges far more than another for the same service, and negotiate accordingly. Providers can benchmark their contracts against real market rates. Researchers and innovators can spend less time cleaning data and more time building on it.
Transparency alone won't fix healthcare costs. But price data has always been only as valuable as it is usable, and this rule moves the market meaningfully in that direction.
At Serif Health, we'll be following the implementation guidance and schema closely. We’re here to answer any questions, and are excited to help our customers put the new data to work as it arrives.