Proposed Transparency in Coverage Rules Seek to Increase the Usefulness of Machine Readable Files

The Departments of the Treasury, Internal Revenue Service (IRS), Health and Human Services (HHS) and Labor (DOL) (together, the departments) published proposed rules on December 23, 2025 (proposed rule), aimed at improving the standardization, accuracy, and accessibility of the pricing information disclosed in the machine readable files (MRFs) mandated under the Transparency in Coverage (TiC) rules (background on the TiC rules and the MRFs can be found in our article here). The proposed rule aligns with Executive Order 14221’s directive to the departments to increase standardization of pricing disclosure information, to ease comparison of pricing disclosure information between health plans, and ensure such data is accurate and meaningful. The comment period for the proposed rule closes on February 23, 2026, and the departments also have indicated that the requirements would not take effect until a year after publication of the final rule. 

Material provisions of the proposed rule include:

• Excluding items and services from in-network MRF data for a provider if the plan or issuer determines it is unlikely that the provider would be reimbursed for such item or service given the provider’s area of specialty (eliminating what is known as “ghost rates”).
• Having third party administrators (TPAs) and issuers create a separate file for each provider network they maintain, allowing that network provider file to be leveraged for all plans and policies using the network, including self-funded plans.
• Emphasizing that in-network MRF rates need to be reflected as dollar amounts unless the provider contract bases compensation on a percentage of billed charges and they are not able to assign a dollar amount to an item or service prior to a bill being generated.
• Aggregating out-of-network payment data by market segment, such that TPAs could aggregate all out-of-network payments for their self-insured business onto one file on behalf of their plan clients.
• Requiring creation of a change log MRF that reflects the data changes between in-network MRF versions.
• Generally adjusting the frequency of MRFs to quarterly.

Additionally, the proposed rule adjusts how MRFs need to be posted online. A plan or issuer would be required to post a plain text file (.txt file) located in the root folder of their website with information on the specific location of the MRFs as well as contact information. The plan or issuer would also need to add a link in the footer of the home page of their website titled “Price Transparency” or “Transparency in Coverage” that routes directly to the publicly available web page that hosts the MRFs. The proposed rule does not appear to override existing guidance that allows a self-funded plan’s TPA to maintain the MRFs on its website on the plan’s behalf, if required under the services agreement with the TPA.

The departments also stated they are seeking comments on whether they should mandate a single file format for MRFs. Specifically, they are contemplating JSON or CSV format.