Final Rule Updates Transparency in Coverage Requirements

On October 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 healthcare price transparency. Key changes affect the machine-readable file (MRF) and price comparison tool requirements.

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

Under the TiC final rules, group health plans and issuers must provide participants, beneficiaries and enrollees with a free internet-based price comparison tool and a paper version upon request. The CAA separately requires plans and issuers to offer a price comparison tool on their website and to provide price comparison guidance by telephone, upon request. In 2021, the Departments called the internet-based tools largely duplicative but noted that the CAA requires cost-sharing information by phone.

Accordingly, the final rule requires that the same information required under the TiC Final Rules also be provided over the phone, upon request, and establishes that doing so satisfies the CAA’s cost-sharing tool requirement (including for grandfathered group health plans and issuers offering grandfathered group and individual health coverage that are not otherwise subject to the TiC Final Rules).

MRF Changes

The 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).

Beginning in 2027, the final rule requires the In-network Rate and Out-of-Network Allowed Amount Files to be updated quarterly (January 1, April 1, July 1, and October 1) rather than monthly. It also 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 requires a Text File containing contact information for the files and a footer with website URLs.

Final Rule Timeline

The price comparison tool changes, including the requirement to provide personalized cost-sharing estimates by telephone upon request, apply to plan years beginning on or after January 1, 2027.

The MRF requirements phase in separately:

• March 6, 2027 – Changes to the In-network Rate and Out-of-network Allowed Amount Files apply, including the new attestation requirement. Initial posting deadline for the revised quarterly In-network Rate and Out-of-network Allowed Amount Files is April 1, 2027.
• September 6, 2027 – Requirements for the new Utilization File, Taxonomy File, Text File, and website footer link begin to apply.
• July 1, 2028 – Initial posting deadline for the Utilization File.

Employer Takeaway

Employers can take the following practical steps to prepare for implementation of the final rule and confirm how their plan’s applicable compliance obligations will be fulfilled:

• Confirm that the insurer or TPA will provide price comparison information by telephone upon request and will update member disclosures and communications by the applicable plan-year deadline.
• Request a written implementation schedule for the 2027 pricing-file changes.
• Confirm that all plan options and provider networks will be included in the new reporting structure.
• Clarify who will host and update the files, maintain website links, and respond to questions.
• Confirm how the required attestations and senior-official identification will be incorporated into the files, and what processes will be used to validate data accuracy.

If you have questions, please reach out to your Hylant representative for further information. Don’t have one? Contact us here.

The above information does not constitute advice. Always contact your employee benefits broker or trusted advisor for insurance-related questions.