On December 23, 2025, the Centers for Medicare & Medicaid Services (CMS), the Department of Labor (DOL) and the Department of the Treasury jointly published proposed rules that would update the 2020 Transparency in Coverage (TiC) requirements for machine-readable files. This blog (Part 1) provides an overview of machine-readable files and the intent of the proposed rules. In addition, this blog highlights how the health care pricing data could be used (ideally) for benchmarking, negotiation and other purposes by self-insured plans. Part 2 will provide an overview of proposed special rules for self-insured group health plans and their service providers for posting in-network prices and out-of-network prices on a public website.

Background FAQs

What is a machine-readable file (MRF)?

Machine-readable file refers to information or data that is in a format (like a spreadsheet) that can be easily processed by a computer without human intervention while ensuring no semantic meaning is lost, according to the Federal Enterprise Data Resources’ glossary.

According to the proposed rule, the large size of many of the required machine-readable files is the most prominent challenge with working with these files. For example, the departments quote a United HealthCare Services, Inc. Transparency in Coverage landing page that says, “Files are in a JSON format and may contain millions of lines of data and be up to 1 terabyte (TB) in size. Please consider your system’s capacity and memory when downloading these files.’’

Who creates/maintains them and when are they updated?

The federal agencies that authored the proposed rule generally assume that service providers perform the MRF-related tasks on behalf of self-insured plans in accordance with a written agreement. The proposal would require MRFs be updated and posted quarterly.

Who uses them?

The health care pricing data in MRFs is not participant-facing, rather it is intended to be processed by analysts and developers.

The path toward consumer-friendly cost comparisons

Under current regulations, MRFs have been difficult to access, navigate and compare which has limited its use and reliability. If finalized, the proposed rules intend to make health care pricing data clearer, meaningful and actionable for tool developers to rely on. The proposed regulations are intended to reduce challenges for existing tool developers and open the market to additional tool developers who can make employer-friendly cost comparison tools.

 “Every person deserves to know what their health care will cost without needing a team of analysts to decode it,” CMS Administrator Dr. Mehmet Oz said in a press release.

By improving accuracy and providing bettercontextualinformation, the departments aim to equip employers (via tool developers) with the information they need to strengthen negotiation and identify cost drivers, creating a more competitive and affordable health system, the press release said.

How health care price transparency data can be utilized

As detailed in the proposed rule, in-network price transparency data organized by provider network is intended to

• Make it easier for employers and plan sponsors to analyze the negotiated rates of different networks to make informed decisions about which plans to offer their employees, potentially favoring networks with more competitive pricing.
• Help employers to bring health care purchasing decisions in house through direct contracting with provider groups.
• Help service providers advise clients on network selection and cost management strategies.

Out-of-network price transparency data offers new insight into actual health care expenditures, including a window into the price of an item or service in the context of an arms-length transaction between a provider and a plan who have not negotiated the rate, and where there is therefore no discount associated with the advantage to a provider of being “in network,” the proposed rule says. The proposal explained the significance of out-of-network price data for various stakeholders as follows:

• Employers and plan sponsors can use this data to benchmark costs, refine benefit designs, and negotiate more effectively with administrators.
• Health care providers can use it to estimate what they might be reimbursed for out-of-network care.
• Service providers can use it to estimate what their participants, beneficiaries, or enrollees might be charged for out-of-network care.

Part 2 will highlight at a high level proposed special rules for self-insured group health plans and their service providers for posting in-network prices and out-of-network prices on a public website. As we wait for a final rule, self-insured plan sponsors might begin to consider planning for compliance monitoring and updating service provider contracts.

Developed by International Foundation Information Center staff. This does not constitute legal advice. Please consult your plan professionals for legal advice.