Norton Rose Fulbright·HEALTHCARE

Transparency in Coverage Final Rules Reshape Payer Pricing Files

CMS, EBSA and the IRS finalized Transparency in Coverage amendments on Oct. 6, 2026, adding network-level rate files, Taxonomy and Utilization files and senior-official attestations, with compliance dates through 2028.

On October 6, 2026, the Internal Revenue Service, the Employee Benefits Security Administration and CMS issued final amendments to the Transparency in Coverage rules for non-grandfathered group plans and individual-market issuers. Per the Norton Rose Fulbright summary, plans and issuers must now publish one in-network rate file per provider network rather than per plan, identified by network name and identifier; new Taxonomy and Utilization files map negotiated rates to providers' specialty taxonomy codes and flag "ghost rates" unlikely to be reimbursed; the out-of-network allowed amount threshold falls from 20 claims to 11, with a six-month reporting period and nine-month lookback; and each file must carry a knowledge-and-belief attestation naming the senior official accountable for accuracy, plus a plain-text location file and a "Price Transparency" homepage link.

Clients in health plans, TPAs, PBMs, rate-file vendors and provider systems should care because no new provider reporting duty is created, yet usable payer data becomes easier to benchmark against Hospital Price Transparency disclosures — making coding and classification inconsistencies more visible, and the attestation language a new enforcement hook. Dates to calendar: effective December 7, 2026; rate-file amendments March 6, 2027; Taxonomy, Text and footer requirements September 6, 2027; Utilization File first posting July 1, 2028; telephone cost-sharing disclosures for plan years from January 1, 2027.

transparency-in-coveragehealth-planscmsprice-transparencyout-of-network-rateshealthcare-regulationno-surprises-act
Read the original firm alert → Friday, October 16, 2026

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