Earlier this summer, the federal government issued a Request for Information (RFI) to gather input on how it should implement one of the most anticipated, and overdue, provisions of the federal Transparency in Coverage (TiC) rule: a requirement for health plans and pharmacy benefit managers (PBMs) to publicly disclose prescription drug pricing data.

At Serif Health, we view this as a pivotal moment. It’s a chance to make drug pricing more visible, actionable, and fair. We submitted two responses:

1. Our independent technical and policy response, grounded in structured data analysis of our June 2025 data and experience working across national payer files; and
2. A co-signed response with Patient Rights Advocate (PRA) and other organizations leading the charge for price transparency.

You can access both responses below:

• Serif Health RFI Response
• PRA Coalition Response

Why This RFI Matters

Prescription drug prices are notoriously opaque, even as they remain a major driver of out-of-pocket costs, benefit design complexity, and employer spending. The original TiC rule, finalized in 2020, required health insurers to disclose negotiated prices for covered medical services, but left prescription drugs for future rulemaking.

Now, CMS and the Departments of Labor and Treasury are finally moving forward. The RFI asks whether insurers are prepared to disclose pharmacy benefit pricing, what data elements should be included, and how rebates, site-of-care variation, and pharmacy-level pricing should be disclosed.

This is not just a regulatory exercise; it’s a chance to make drug prices usable and transparent in the same way medical benefit prices have begun to shift over the past four years.

What Serif Recommended

In our independent response, we offered both a technical assessment and clear recommendations, drawing on our structured and enriched database of Transparency in Coverage files and industry-standard reference data sources.

Key Points:

• Coverage is Real: As of June 2025, our analysis showed that nearly 47% of the NDCs reported through CMS’ RxDC program already have some negotiated rates visible in TiC data. Compare this to physician-administered drugs billed under the medical benefit (e.g., J-codes), coverage is essentially 100% complete when compared to Medicare’s Part B ASP data.
• Variation is Substantial: Drug prices vary dramatically by payer, provider, and site of care. Without a requirement to disclose both medical and pharmacy benefit rates, this variation remains hidden.
• Data Structure Matters: We advocated for required fields like days’ supply, dosage unit, and rebate pass-through flags, as well as a public crosswalk between HCPCS and NDC codes to enable meaningful comparisons.
• The Infrastructure Exists: Based on our work across over 200 US commercial payers and billions of rate records, we emphasized that the majority health plans and PBMs already have the infrastructure needed. What’s missing is final schema guidance and meaningful enforcement of both existing and anticipated regulatory requirements.

Standing with the Transparency Community

In parallel with our own submission, we co-signed and contributed to the PRA-led coalition response. PRA’s submission emphasized a number of critical improvements that would make the data more usable and accurate:

• Eliminating the 20-claim minimum threshold, which suppresses reporting for rare and high-cost drugs, both of which reflect a high share of total US drug spending
• Ensuring reporting at both the pharmacy and overall plan level, to surface variation and support full accountability
• Requiring rebate breakdowns, with fields that clearly show how discounts, chargebacks, and administrative fees impact pricing
• Aligning prescription drug reporting with existing payer- and hospital-disclosed medical transparency, to support cross-benefit comparisons and site-of-care optimization

PRA's submission also called for standardized formats for dosage units and supply duration, and reaffirmed that the infrastructure for drug price transparency is already largely in place: a message Serif strongly echoes.

We are proud to stand alongside PRA, Employers' Forum of Indiana, 3 Axis Advisors, and others committed to reshaping how healthcare prices are communicated and acted on.

What Comes Next

At Serif, we’re already helping life sciences, digital health, pharmacy, and provider organizations make use of what’s disclosed and we’re building for what’s coming next. This RFI is a key step, but it’s not the finish line. We’ll continue to advocate for implementation that is ambitious, structured, and enforceable.

In the meantime, if you work in access, benefit design, digital health, or data analytics and want to understand what’s currently available or how this data can help your team, we’d love to hear from you. Please reach out to hello@serifhealth.com or book time here. Also feel free to check out our sample data on our web platform Signal.