On Oct. 5, 2026, the Departments of Labor, Health and Human Services, and the Treasury (Departments) released a final rule to improve price transparency requirements for non-grandfathered group health plans and health insurance issuers. The rule amends the 2020 Transparency in Coverage (TiC) Final Rules and implements President Donald Trump’s February 2025 executive order on improving health care price transparency. Key changes affect the machine-readable file (MRF) and price comparison tool requirements.
Applicability
- The price comparison tool changes apply to plan years beginning on or after Jan. 1, 2027.
- The MRF changes apply in phases:
- Changes to the In-network Rate and Allowed Amount Files, as well as the new attestation requirement, apply beginning March 6, 2027, with the first quarterly posting due April 1, 2027.
- The Utilization File, Taxonomy File, Text File and website footer link apply beginning Sept. 6, 2027.
- The Utilization File must be posted annually beginning July 1, 2028.
- Changes to the In-network Rate and Allowed Amount Files, as well as the new attestation requirement, apply beginning March 6, 2027, with the first quarterly posting due April 1, 2027.
- The Utilization File, Taxonomy File, Text File and website footer link apply beginning Sept. 6, 2027.
- The Utilization File must be posted annually beginning July 1, 2028.
Background
Group health plans and health insurance issuers are subject to many transparency and consumer protection requirements under the TiC Final Rules and the Consolidated Appropriations Act, 2021 (CAA), both of which were finalized in late 2020. The reforms broadly apply to group health plans (including fully insured, self-insured and level-funded plans) and issuers of group and individual coverage. In general, most employers rely on their issuers, third-party administrators (TPAs), and other service providers to satisfy these obligations, but should confirm that those arrangements are in writing and monitor compliance.
Price Comparison Tool Changes
MRF Changes
New Transparency FAQs Set Timeline and Format for Updated MRFs
- The In-network Rate and Allowed Amount Files must be updated quarterly rather than monthly, starting April 1, 2027.
- The new Taxonomy and Text Files must be published beginning Oct. 1, 2027.
- The new Utilization File must be published annually beginning July 1, 2028.
- Plans and issuers will be expected to publish the Prescription Drug File starting in December 2027 and monthly thereafter.
The original 2020 TiC final rules require group health plans and issuers to disclose detailed pricing information on a public website in three separate MRFs: an In-network Rate File (containing negotiated rates for covered items and services), an Allowed Amount File (containing historical payments to and billed charges from out-of-network providers), and a Prescription Drug File (containing negotiated rates and historical net prices for covered drugs). Plans and issuers are expected to continue complying with these requirements until April 1, 2027. Most employers rely on their insurance carriers and third-party administrators to provide and post the MRFs.
The Oct. 6, 2026, final rule adds a Utilization File and a Taxonomy File, and requires plans and issuers to attest that their MRFs are accurate and complete. To improve the findability of MRFs, including the Prescription Drug File, the final rule also requires a Text File containing contact information for the files and a footer with website URLs. In addition, the In-network Rate and Allowed Amount Files must be updated quarterly rather than monthly.
- In-network Rate and Allowed Amount Files: These move from monthly to quarterly posting. The first updated MRFs must be published on April 1, 2027, and quarterly thereafter (i.e., July 1, 2027, Oct. 1, 2027, Jan. 1, 2028, and April 1, 2028);
- Taxonomy File: This new file must be published on Oct. 1, 2027, and quarterly thereafter;
- Text File: This new file must be published on Oct. 1, 2027, and within seven calendar days of any updates; and
- Utilization File: This new file must be published annually on July 1, beginning July 1, 2028.
The FAQs confirm that JSON is the specified format in which plans and issuers should publish their MRFs, with the exception of the Text File which is required to be published in .txt format.
Posting Machine-Readable Files
- First file: In-network provider negotiated rates for covered items and services (the “In-network Rate File”);
- Second file: Historical payments to and billed charges from out-of-network providers (the “Allowed Amount File”); and
- Third file: In-network negotiated rates and historical net prices for covered prescription drugs (the “Prescription Drug File”).
Nonduplication Rule
- Fully insured plans: A fully insured group health plan satisfies the MRF requirements if the issuer offering the coverage is required to provide the information pursuant to a written agreement between the plan and issuer. Accordingly, if a plan sponsor and an issuer enter into a written agreement under which the issuer agrees to provide the information required and the issuer fails to provide full or timely information, then the issuer, not the plan, has violated the TiC Final Rules’ disclosure requirements.
- Self-insured plans: A self-insured group health may satisfy the MRF requirements by entering into a written agreement under which another party (such as a TPA) will make public the required information. But the plan must monitor the other party to ensure the entity is providing the required disclosures. It is ultimately the responsibility of the health plan to ensure that the third party provides the required information.
Website Posting
Final Rule to Improve Transparency
Implementation FAQs and New Posting Schedule
- In-network Rate and Allowed Amount Files: These move from monthly to quarterly posting. The first updated MRFs must be published on April 1, 2027, and quarterly thereafter (i.e., July 1, 2027, Oct. 1, 2027, Jan. 1, 2028, and April 1, 2028);
- Taxonomy File: This new file must be published on Oct. 1, 2027, and quarterly thereafter;
- Text File: This new file must be published on Oct. 1, 2027, and within seven calendar days of any updates; and
- Utilization File: This new file must be published annually on July 1, beginning July 1, 2028.
Prior Enforcement Safe Harbor for In-Network Rates
LINKS & RESOURCES
- TiC Final Rules from November 2020
- FAQ guidance from September 2023 ending certain enforcement relief for providing the MRFs
- Final rule from October 2026 that updates the TiC Final Rules and revises MRF requirements
- FAQ guidance from October 2026 explaining the timeline and format for updated MRFs
This article is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. © 2026 Zywave, Inc. All rights reserved.