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On October 6, 2026, the Departments (IRS, DOL, CMS, and HHS) released the Transparency in Coverage (TiC) Final Rule. This final rule reflects stakeholder feedback received in response to the Transparency in Coverage (TiC) proposed rule issued on December 19, 2025. Generally, the TiC rules intend to improve accessibility, standardization, and reliability of public pricing disclosures contained in machine-readable files (MRFs) and a self-service tool that must be provided to the public by non-grandfathered group health plans and health insurance issuers. The TiC final rule builds on a previous TiC final rule issued on November 12, 2020, and is consistent with the President’s Executive Order 14221, “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information”.
Even though an employer plan sponsor may ultimately be responsible for ensuring adherence to these TiC rules, most carriers/TPAs will take responsibility for compliance under these rules so long as they are willing to agree, in writing, to perform these duties on behalf of the employer plan sponsor. Keep reading for a general overview of these rules and helpful action items for employer plan sponsors to consider.
Background of current requirements
Generally, under the current TiC rules, non-grandfathered group health plans and health insurance issuers must post machine-readable files (MRFs) on a monthly basis containing the following information for each plan or coverage: (1) an in-network rate file disclosing negotiated in-network rates for covered items and services; (2) an allowed amount file disclosing out-of-network allowed amounts and associated billed charges; and (3) a prescription drug file disclosing in-network rates and historical net prices for covered items and services.
Note: Enforcement of the prescription drug file is being enforced on a “case-by-case basis, as the facts and circumstances warrant.”
Modifications to file requirements
The Departments’ final rule to modify the current TiC rules includes the following:
- Reduce the size of in-network machine-readable files. Currently, large In-network Rate Files contained in the required MRFs include provider rates for services they are unlikely to perform (e.g., podiatrists listed with rates for cardiac surgery). To address this issue, the final rule requires group health plans/issuers to exclude certain items and services that a specialty area service provider would likely not be reimbursed for. In addition, a Utilization File for each In-network Rate File would include a list of all providers that submitted and received a reimbursement for the most recent plan year.
- Report in-network rates by network. Plans and issuers must submit a single In-Network Rate File for each provider network they maintain or contract with, rather than a separate file for each plan. This approach aligns with the Hospital Price Transparency rule's network-based reporting requirements.
- Increase the usability and accessibility of files. The final rule states that plans and issuers must post a utilization file within each Out-of-Network Allowed Amount File. Account based plans and excepted benefit plans would be excluded from these requirements. The Out-of-Network Allowed Amount File would be subject to the following rules:
- Payers must combine their Allowed Amount File by insurance market segment type (e.g., individual, small group, large group, and self-insured).
- A plan or issuer must report out-of-network historical payment data if there are 11 or more claims per item or service (previously 20), which would help to increase the amount of out-of-network data to assist researchers and academics to provide helpful analyses to the public.
- Require group health plans/issuers to report the plan’s product type (e.g., HMO, PPO, EPO) in both an In-network Rate File and Out-of-network Allowed Amount File.
Plans (or those entities that have been delegated the duty to post MRFs) and issuers must also publish a plain text (.txt) file on their website that identifies the location of the MRFs and includes plan or issuer contact information, enabling individuals to submit questions or report issues related to the files. The website must also contain a link in the footer of the homepage titled "Price Transparency" or "Transparency in Coverage" that directly links to the data files.
- Single file format adoption. Previously, plans and issuers could provide plan information in various formats (e.g., JSON, XML, CSV). The final rule requires that all files be provided in a single, non-proprietary, and open-standard format, as specified in agency guidance. The preamble to the final rule indicates the Departments intend to adopt the JSON format for all MRFs in future guidance.
- Reduction in reporting frequency. Rather than requiring the In-Network Rate File and Out-of-Network Allowed Amount File to be updated and posted monthly, the final rule only requires these files to be updated and posted on a quarterly basis. The Departments declined to include in the final rule a proposal that would have required plans and issuers to create a change log file outlining any updates to rates between file reporting periods. These changes in the final rule significantly reduce the reporting burden on plans and issuers. The government states that due to these modifications, plans and issuers could save upwards of $174.5M annually, due to this reduction in reporting cadence under the TiC final rule.
Accountability and accuracy of information provided
The most significant new requirement in the final rule is that plans and issuers must include an attestation in each In-network Rate, Out-of-Network Allowed Amount, Prescription Drug, Taxonomy, and Utilization MRF, and certify that to the "best of their knowledge and belief, the plan or issuer has included all applicable information in accordance with the requirements, and the information encoded is true, accurate, and complete as of the date in the file." This attestation must include the name of the plan’s or issuer’s “chief executive officer, president, or senior official designated to oversee the encoding of true, accurate, and complete data." Group health plan sponsors and insurance carriers are ultimately responsible for complying with the TiC rules. However, the final rule allows plan sponsors, under the terms of a written agreement, to delegate the responsibilities associated with TiC compliance to an insurer or third-party service provider (e.g., TPA). The final rule also allows a plan to delegate the authority to certify and attest to the accuracy of MRF datasets to an insurance carrier’s or third party's CEO, president, or other senior official, rather than requiring that responsibility to remain with a senior official of the group health plan sponsor.
Final rule related to disclosures to participants, beneficiaries, and enrollees
The 2020 TiC final rule required plans and issuers to make cost‑sharing information available via an online self‑service tool (and on paper upon request), accompanied by notices explaining data limitations, beginning in January of 2023. Thereafter, the No Surprises Act also required cost‑sharing information to be provided over the phone.
To ensure consistency in those requirements, the final rule requires plans and issuers to align the information mandated under the TiC rules with the No Surprises Act’s cost-sharing tool provision, so that the same cost-sharing information under both laws is provided whether viewed online, on paper, or by telephone, upon request. The 2026 TiC final rule also requires balance billing notices to reflect new federal protections against balance billing in certain circumstances.
Effective dates of provisions within the TiC final rule
The TiC final rule provides various effective dates for the above provisions. The changes relating to individual disclosures apply to plan years (policy years in the individual market) beginning on or after January 1, 2027. The provisions related to the In-network Rate and Out-of-network Allowed Amount Files, along with the attestation requirement, apply five months following the date of publication of the final rule, which is March 6, 2027. The provisions related to the new contextual files (taxonomy, utilization, and text) apply 11 months following the date of publication of the final rule, which is September 6, 2027.
Action plan
Many carriers/TPAs have been publishing group health plans’ MRF information (including MRF data sets) and maintaining an online self-service tool on their public website since July of 2022. That said, employer plan sponsors should confirm that their carriers and TPAs are complying with both the current and final rule requirements, including ensuring that all required data elements are accurately reflected in the MRFs, before the final rule's applicable compliance deadlines take effect. This includes confirming that the internet-based pricing tool will be available over the phone by January 1, 2027. Additionally, employer plan sponsors should ensure that any future health plan RFPs and carrier/TPA contracts include a written agreement that the carrier/TPA is taking on the responsibility of disclosing “true, accurate, and complete” TiC information, including: updating datasets, text files and hyperlinks in the MRFs posted on their public website on behalf of the group health plan, and attesting to the accuracy of such information contained within the MRFs, starting with the first calendar quarter following March 6, 2027.
The final rule, published on October 6, 2026, in the Federal Register, along with an additional link to the CMS Newsroom factsheet summarizing key provisions that are contained within the TiC final rule can be found, below:
October 6, 2026 TiC Final Rule
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