The proposed CMS-9882-P rule seeks to address structural limitations in current Transparency in Coverage (TiC) machine-readable files (MRFs) by improving usability, reducing file sizes, and introducing greater standardization.
TALON strongly supports the Departments’ effort to reform the structural failures of the current transparency framework. While the proposal represents meaningful progress, additional requirements around context, accountability, and enforcement are necessary to ensure transparency data becomes interpretable and actionable for employers, researchers, and plan sponsors.
What CMS-9882-P Proposes
CMS-9882-P introduces several changes designed to improve the usability of Transparency in Coverage data, including:
- Reducing machine-readable file sizes by filtering clinically implausible data
- Shifting from plan-level reporting to network-level reporting to reduce duplication
- Introducing new Utilization and Change-Log files to improve data validation and processing
- Standardizing data structures and reporting formats
- Improving the overall interpretability of healthcare pricing information
These reforms represent meaningful progress toward making price transparency data more usable across the healthcare ecosystem.
Key Provisions Supported (With Recommended Enhancements)
TALON supports several core proposals included in CMS-9882-P but urges specific enhancements to ensure data integrity and operational usefulness.
Clinical Plausibility Filtering
Filtering clinically implausible provider-service combinations (“ghost rates”) could reduce file sizes by 60–80% and significantly improve usability. TALON recommends making these filters auditable against NPPES taxonomy codes to prevent payers from relying on proprietary internal mappings that could exclude relevant provider data.
Network-Level Reporting
To prevent file proliferation, TALON supports shifting from plan-level to network-level reporting. CMS should define “network” using a materiality threshold for rate divergence and require stable, persistent network identifiers to enable consistent tracking across reporting periods.
Utilization and Change-Log Files
TALON supports the introduction of Utilization Files to confirm active provider participation and Change-Log Files to enable incremental data processing. These files will require standardized schemas to ensure operational usefulness.
JSON Format Requirement
TALON believes JSON should remain mandatory for In-Network Rate Files due to their nested relational hierarchy. CSV formats are only appropriate for simpler tabular datasets such as Allowed Amount Files.
Critical Gaps in the Proposed Rule
TALON identifies four foundational gaps that must be addressed to make transparency data interpretable and actionable.
Mandatory Reimbursement Methodology Disclosure
Negotiated rates are currently uninterpretable without knowing whether they are calculated using fee-for-service schedules, DRG methodologies, capitation, or other payment structures. TALON recommends adding a standardized enumerated field identifying reimbursement methodology.
Dollar-Denominated Rates
Whenever possible, negotiated rates should be expressed in dollar values. Percent-of-charge arrangements should require disclosure of the underlying charge master reference.
Executive Attestation
To strengthen accountability, a Chief Compliance Officer, or equivalent executive of the controlling entity, should certify the accuracy and completeness of reported data, rather than the Plan Sponsor.
Enforcement Mechanisms
TALON recommends structured compliance audits, defined correction windows, and escalating civil monetary penalties to ensure consistent compliance.
Incentive Alignment and Market Impact
Healthcare price transparency alone does not change market behavior without aligned incentives.
TALON encourages the Departments to clarify the permissibility of savings-based reward structures, such as rewarding participants for selecting lower-cost, high-quality providers. Aligning transparency with financial incentives would strengthen market discipline and support more informed healthcare purchasing decisions.
We believe CMS-9882-P represents an important step toward making price transparency data usable. By strengthening contextual data requirements, enforcing accountability, and aligning incentives, the rule can move price transparency beyond a compliance exercise and toward functioning market infrastructure for healthcare pricing.