Transparency 1.0 Published Prices. 2.0 Makes Them Usable.
On October 5, 2026, TALON was in Washington, D.C. as federal leaders announced the next phase of the Transparency in Coverage framework. The most important change is not that more pricing data will exist. It is that a named executive will now stand behind it, and the market will finally be able to use it.
What changed
From More Data to Better Data
CMS identified three barriers in the original framework: files too large to access, data too ambiguous to interpret, and payer disclosures that did not line up with hospital disclosures. The 2026 final rule (CMS-9882-F) addresses each one.
01
Network-level reporting
In-network Rate Files move from plan level to network level, removing the duplication that made files unusable. Every network is reported once, with a common name and identifier.
02
Real rates only
Provider-rate combinations that would never be paid must be excluded. Rates must be dollar amounts, not percentages of billed charges. New Taxonomy and Utilization Files add the context that was missing.
03
A named executive attests
Each file must state that the data is true, accurate, and complete, encoded with the name of the plan's or issuer's CEO, president, or designated senior official. Quarterly, file by file.
THE ACCOUNTABILITY SHIFT
Soon, An Executive Signs for Your Pricing Data. Can They Stand Behind It?
The duty to publish accurate prices has not changed. What changed is that a named person now certifies it. The rule does not create a new penalty. It attaches an executive's name to files that regulators, employers, and advisors already download and benchmark.
An attested file that does not match paid claims becomes a renewal conversation, not only a compliance one.
Schema conformity proves a file is structured correctly. It does not prove the prices inside it are real. Most validation stops at the first question. The attestation is about the second.
Six questions before signing
1. Do published rates reconcile to adjudicated claims?
2. Have provider-rate combinations that will never be paid been excluded?
3. Is every network reported once, with a common name and identifier?
4. Are any rates still expressed as a percentage of billed charges?
5. Can the files be regenerated and re-attested quarterly without manual rework?
6. Who signs, and is the delegation documented?
KEY DATES
The Timeline from Here
Binding dates come from the rule text. Prescription Drug File dates come from CMS statements and should be treated as planning dates until guidance confirms them.
-
December 7, 2026Effective
Final rule takes effect. Current MRF requirements continue until each applicability date.
-
January 1, 2027Plan years on or after
Cost-sharing information by phone. Self-service tool compliance also satisfies the No Surprises Act price comparison tool requirement.
-
March 6, 2027Phase 1
Executive attestation applies. Network-level files, excluded provider-rate combinations, dollar-amount rates, quarterly cadence, single file format.
-
May 2027CMS plan
Prescription Drug File schema expected to be finalized. Schema development begins November 2026.
-
September 6, 2027Phase 2
Taxonomy File, Text File, and footer link. First Utilization File posting July 1, 2028, then annually.
-
December 2027CMS expectations
Plans and issuers expected to begin publishing the Prescription Drug File, monthly thereafter.
COMPLIANCE IS NOT THE END GOAL
A Compliant File is Not a Functioning Marketplace
Federal requirements establish the disclosure framework. The private market has to turn that information into something useful. The question is no longer whether organizations can publish the required data. It is what employers, consumers, advisors, health plans, and TPAs can do once the data becomes usable.
Published pricing
Curated pricing intelligence
Employer insight
Member guidance
Upfront cost
Healthcare decision
Payment
Claims validation
The long-term destination is not price transparency. It is price certainty.
WHAT THIS MEANS FOR YOU
The Same Rule Lands Differently in Every Seat
___
Health Plans and Issuers
A named executive signs for file accuracy beginning March 6, 2027. The CMS validator checks format. The attestation is to accuracy. Employers and advisors are already benchmarking your files.
This helps your prices make sense to employers and regulators alike.
___
Third-Party Administrators
A self-funded plan may delegate the attestation to its TPA only by written agreement, and liability stays with the plan. Employer groups will ask whether you can stand behind the files and use the data for benchmarking, back-testing, and steerage.
This lets you guide employers without owning prices you do not set.
___
Employers and Benefits Advisors
Network-level rate files make it possible to see what a plan actually pays relative to the market, where the outliers are, and whether network economics match what was represented. The topic moves from compliance to purchasing strategy.
This turns market behavior into defensible advice.
PHARMACY IS THE NEXT FRONTIER
The Prescription Drug File Now Has a Date
CMS expects plans and issuers to begin publishing the Prescription Drug File in December 2027, monthly thereafter, on a schema it plans to finalize around May 2027. The file requires negotiated rates and historical net prices for every covered drug, by NDC and by pharmacy, inclusive of rebates and other concessions.
The data requirements did not change.
The accountability requirements did.
December 2027 is a planning date.
BRIEFS AND RESOURCES
TALON's Analysis, Written to be Forwarded
CMS expects plans and issuers to begin publishing the Prescription Drug File in December 2027, monthly thereafter, on a schema it plans to finalize around May 2027. The file requires negotiated rates and historical net prices for every covered drug, by NDC and by pharmacy, inclusive of rebates and other concessions.
Evidence Your Designated Executive Can Read Before Signing
TALON ingests your current In-network Rate and Allowed Amount files, reconciles a sample against your paid claims, scores the files across the dimensions the rule targets, and returns a findings report. A 20-minute diagnostic conversation, in advance of March 6, 2027.
99.9%
25B+
