In February 2025, President Donald Trump issued an executive order (EO) directing the Departments of Labor, Health and Human Services, and the Treasury (Departments) to implement and enforce health care price transparency regulations. The Departments have started issuing new transparency guidance in response to the EO’s directives.
Transparency Regulations
- Machine-readable files (MRFs): Health plans and issuers must disclose detailed pricing information in three MRFs on a public website. These MRFs provide information on negotiated rates for in-network providers, billed charges and allowed amounts from out-of-network providers, and negotiated rates and prices for prescription drugs. However, enforcement of the MRF related to prescription drug costs has been delayed; and
- Self-service price comparison tool: Health plans and issuers must make an internet-based self-service tool available to participants, beneficiaries and enrollees to disclose the personalized price and cost-sharing liability for covered items and services, including prescription drugs.
The Executive Order
- Require the disclosure of actual prices of items and services, not estimates;
- Ensure pricing information, including prescription drug pricing, is standardized and easily comparable; and
- Update enforcement policies to ensure compliance with price transparency requirements.
Recent Developments
On May 22, 2025, the Departments issued a request for information (RFI) on the implementation of the MRF related to prescription drug costs. The RFI seeks public input regarding the prescription drug price disclosure requirements, including information on existing prescription drug file data elements and the ability of health plans to access necessary data for reporting. The Departments also released guidance on implementing an enhanced technical format for MRFs related to in-network providers and out-of-network allowed amounts and billed charges. According to the Departments, this new format will promote transparency by eliminating meaningless or duplicative data from the files.
Related:
- (May 2025) Feds announce new data format update for employer health plan prices – Regulators hope improved machine-readable files will help patients do a better job of shopping for care.
- (May 2025) Trump’s PBM compensation moves: Evolving regulations and compliance obligations – President Trump’s recent executive order represents the latest in a series of efforts to increase transparency and accountability within the drug supply chain.
- (February 2025) Trump calls for stronger enforcement of health care price posting rules – The new executive order could affect enforcement of regulations that apply to hospitals and health plans.
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. ©2025 Zywave, Inc. All rights reserved.
