Federal Agencies Propose Changes to Health Plan Price Transparency Rules

Federal agencies have proposed changes to federal health care price transparency rules that would affect employer-sponsored group health plans—particularly self-insured plans—as regulators frame the changes as a technical effort to improve data usability.

The proposed rules, issued jointly by the Departments of Labor, Treasury, and Health and Human Services, would revise the 2020 Transparency in Coverage regulations by adding new disclosure files, expanding required data elements and aligning plan reporting more closely with hospital price-transparency requirements. If finalized, the changes would deepen federal oversight of health plan pricing and operations and would place new compliance and governance demands on plan sponsors.

From ‘Price Transparency’ to Plan Transparency

The original Transparency in Coverage rules require health plans and issuers to publish machine-readable files showing in-network negotiated rates, out-of-network allowed amounts and prescription drug pricing. While those disclosures created larger amounts of pricing data, regulators said the files were too large, lacked context and were difficult to use.

The new proposal goes much further, according to the filing. Rather than simply refining pricing data, it would require health plans to disclose how pricing works in practice, including utilization patterns, provider classifications and enrollment levels.

Among the proposed changes is the introduction of mandatory “contextual” files that must accompany in-network rate disclosures, which would include:

• Change-log files to document all changes to negotiated rates from one reporting period to the next;

• Utilization files showing 12 months of claims history by billing code, National Provider Identifier and Tax Identification Number, and place of service; and
• Provider taxonomy files revealing the internal rules used by plans to determine which provider specialties are eligible to be paid for specific services.

Together, disclosure of this information could give regulators, researchers and third parties improved insight into how employer health plans operate behind the scenes—not just what they pay, according to the proposed rules.

Enrollment Counts Must Be Disclosed

The proposal would also require, for the first time, plans to disclose current enrollment totals associated with each provider network included in the in-network rate files.

Enrollment size is a key factor in negotiating leverage with providers, and disclosure could enable comparisons across employers, insurers and markets. For midsize employers, this could expose competitive positioning in ways that were previously confidential.

Meanwhile, to reduce what regulators view as misleading or unusable data, plans would be required to exclude negotiated rates for services a provider is unlikely to perform based on specialty classification.

While intended to clean up data, the change puts new emphasis on how plans and third-party administrators define provider roles—decisions that could now carry regulatory and compliance implications if challenged.

Some Relief on Reporting Frequency, Expanded Out-of-Network Disclosures

The proposed rules would reduce the reporting frequency for in-network and out-of-network files to quarterly from monthly, although prescription drug files would remain monthly.

The proposed rules would also expand out-of-network reporting by:

• Lowering the minimum number of claims required for disclosure;
• Extending reporting and lookback periods; and
• Requiring aggregation at the market level, rather than by plan.

These changes would make out-of-network pricing more visible and comparable, potentially influencing disputes under the No Surprises Act and provider negotiations, according to the filing.

Plans would be required to provide price comparison information by phone, not just online or on paper. The filing stated that meeting this requirement would also satisfy the No Surprises Act’s price comparison obligations—even for grandfathered plans.

This change will likely require additional call center training and coordination with TPAs and vendors.

Regulators estimate the proposed rules would add more than $900 million in one-time compliance costs and roughly $68 million in ongoing annual costs across the employer-provided health plan system. While those costs are formally attributed to “plans and issuers,” self-insured employers are expected to absorb much of the impact through higher administrative fees and vendor charges, according to the proposal.

Comments on the proposed rules are due 60 days after its publication in the Federal Register, which occurred on December 23, 2025.