{
    "schema": "amendsignal.record/1",
    "generated_on": "2026-11-03",
    "publisher": {
        "name": "AmendSignal",
        "url": "https://amendsignal.com/"
    },
    "notice": "Coverage is limited, so a missing record does not mean nothing changed. General information, not legal advice. Check the official source. Please cite the record's url.",
    "change": {
        "id": 30,
        "url": "https://amendsignal.com/changes/employee-benefits-security-administration-and-partner-agencies-propose-changes-to-health-plan-price/",
        "title": "Employee Benefits Security Administration and partner agencies propose changes to health plan price transparency rules",
        "change_type": "proposed_rule",
        "change_type_label": "Proposed rule",
        "status": "proposed",
        "status_label": "Proposed",
        "status_statement": "As of our last check on November 3, 2026, this is a proposal, not a requirement. Comments closed March 2, 2026.",
        "significance": "Proposed, nothing required yet",
        "jurisdiction": {
            "code": "US",
            "name": "United States"
        },
        "authority": {
            "name": "Employee Benefits Security Administration",
            "short_name": "EBSA"
        },
        "identifiers": [
            {
                "type": "fr_document_number",
                "label": "FR document",
                "value": "2025-23693"
            },
            {
                "type": "fr_citation",
                "label": "Citation",
                "value": "90 FR 60432"
            },
            {
                "type": "rin",
                "label": "RIN",
                "value": "0938-AV64"
            },
            {
                "type": "rin",
                "label": "RIN",
                "value": "1210-AC30"
            },
            {
                "type": "rin",
                "label": "RIN",
                "value": "1545-BQ55"
            },
            {
                "type": "docket_id",
                "label": "Docket",
                "value": "REG-107111-25"
            },
            {
                "type": "docket_id",
                "label": "Docket",
                "value": "CMS-9882-P"
            },
            {
                "type": "cfr_citation",
                "label": "CFR",
                "value": "26 CFR 54"
            },
            {
                "type": "cfr_citation",
                "label": "CFR",
                "value": "29 CFR 2590"
            },
            {
                "type": "cfr_citation",
                "label": "CFR",
                "value": "45 CFR 147"
            }
        ],
        "dates": [
            {
                "type": "publication",
                "label": "Published",
                "value": "2025-12-23",
                "precision": "day"
            },
            {
                "type": "comment_close",
                "label": "Comments due",
                "value": "2026-03-02",
                "precision": "day"
            }
        ],
        "in_short": {
            "what_changed": "The Internal Revenue Service, the Employee Benefits Security Administration and the Centers for Medicare & Medicaid Services propose changes to the Transparency in Coverage price disclosure rules for health plans. The proposal would organize public price files by provider network, add new context files and data, post most files quarterly instead of monthly, and add cost-sharing estimates by phone.",
            "whos_affected": "Non-grandfathered group health plans and health insurers would make the changes. Employers that sponsor self-insured plans would mostly rely on their third-party administrators. Grandfathered plans are touched only by the phone and price comparison tool provisions.",
            "what_to_do": "This proposed rule creates no new duties yet, and the current rules continue to apply. Comments are due March 2, 2026 (extended from February 23, 2026). Sponsors of self-insured plans may want to ask their administrators how they would comply if the proposal is finalized."
        },
        "summary": "The Employee Benefits Security Administration, the Internal Revenue Service and the Centers for Medicare & Medicaid Services propose to revise the Transparency in Coverage rules for group health plans and health insurers. The proposal would reorganize the public price files and add context files to them, move most postings from monthly to quarterly, and require cost-sharing estimates by phone. It is only a proposal: comments are due March 2, 2026, and the current rules stay in place until a final rule applies.",
        "business_functions": {
            "state": "limited",
            "functions": [
                {
                    "slug": "benefits",
                    "name": "Benefits"
                },
                {
                    "slug": "legal-and-compliance",
                    "name": "Legal and compliance"
                }
            ]
        },
        "added_on": "2026-11-03",
        "updated_on": null,
        "updates_in_progress": null,
        "last_checked": "2026-11-03",
        "record_url": "https://amendsignal.com/changes/employee-benefits-security-administration-and-partner-agencies-propose-changes-to-health-plan-price/record.json",
        "what_changed": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The comment deadline was February 23, 2026, and is now March 2, 2026.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/02/25/2026-03798/private-health-insurance-transparency-in-coverage-extension-of-comment-period",
                        "locator": "DATES",
                        "excerpt": "The comment period for the December 23, 2025 proposed rule (90 FR 60432) is extended to March 2, 2026."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Plans and insurers would have to give cost-sharing estimates by phone, at the customer assistance number printed on the plan identification card, in addition to the online tool and paper. They could limit answers to no fewer than 20 providers per day.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "I.B.2. Summary of the Major Provisions",
                        "excerpt": "the Departments propose to add a new paragraph at (b)(2)(iii) under this section to require plans and issuers to make available to participants, beneficiaries, and enrollees the cost-sharing estimates and other disclosures required under paragraph (b)(1) via a telephone number"
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A2(b)(2)(iii)",
                        "excerpt": "may limit the number of providers with respect to which cost-sharing information for covered items and services is provided to no fewer than 20 providers per day"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Meeting the online, paper and phone cost-sharing disclosure duties would also satisfy the No Surprises Act price comparison tool requirement.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "SUMMARY",
                        "excerpt": "establish that the satisfaction of such requirement also satisfies the requirements of section 114 of the No Surprises Act"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The balance billing statement that accompanies cost-sharing estimates would be reworded to reflect both State and Federal law.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "I.B.2. Summary of the Major Provisions",
                        "excerpt": "to require the disclaimer, described in that paragraph, to state that the cost-sharing information does not account for potential additional amounts in situations where applicable State and Federal law allow out-of-network providers to balance bill participants, beneficiaries, and enrollees."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "In-network rate files would be posted once for each provider network instead of for each plan. They would add the network name, the product type and enrollment counts, and they would leave out rates for providers who are unlikely to be paid for a service given their specialty.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "III.C.1.a. Reducing File Size",
                        "excerpt": "the Departments propose to amend the introductory language of paragraph (b)(1)(i) to require plans and issuers to make an In-network Rate File available for each provider network maintained or contracted by the plan or issuer."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "SUMMARY",
                        "excerpt": "adding new contextual files and additional data elements like product type, network name, and enrollment counts; changing the reporting level for aggregation of data; removing in-network rates for unlikely provider-to-service mappings"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Out-of-network allowed amount files would be reported by health insurance market instead of by plan. The claims threshold would drop from 20 to 11 claims, the reporting period would grow from 90 days to 6 months, and the lookback would grow from 180 days to 9 months.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "I.B.5. Public Disclosure of Out-of-Network Allowed Amounts",
                        "excerpt": "require plans and issuers to report out-of-network allowed amounts and billed charges at the health insurance market level, rather than the plan or policy level"
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "I.B.5. Public Disclosure of Out-of-Network Allowed Amounts",
                        "excerpt": "lower the threshold for including claims in the Allowed Amount File from 20 to 11 different claims per item or service, and increase the reporting period from 90 days to 6 months and the lookback period from 180 days to 9 months."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "In-network rate and allowed amount files would be posted quarterly instead of monthly. The prescription drug file would stay monthly.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "I.B.3. Transparency in Coverage--Requirements for Public Disclosure",
                        "excerpt": "proposed paragraph (b)(4)(i) would amend the required reporting frequency for the In-network Rate and Allowed Amount Files under paragraphs (b)(1)(i) and (b)(1)(ii) from monthly to quarterly but would not propose any changes to the monthly reporting frequency for the prescription drug file"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Four new files would be required: a change log, a utilization file, a taxonomy file and a plain text file pointing to the price files. A footer link on the plan's or insurer's website would also be required, and the files would have to be open to automated scripts and web crawlers.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "III.C.7. Contextual Files: Change-log, Utilization, Taxonomy, and Text",
                        "excerpt": "Specifically, the Departments propose to add new paragraphs (b)(2)(i) through (iv) requiring: a Change-log File at paragraph (b)(2)(i), a Utilization File at paragraph (b)(2)(ii), a Taxonomy File at paragraph (b)(2)(iii), and a Text File at paragraph (b)(2)(iv)."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(b)(3)",
                        "excerpt": "must be included as a link in the footer on the home page of the group health plan's or health insurance issuer's website"
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(b)(3)(ii)",
                        "excerpt": "The machine-readable files must be publicly available and accessible to any person, automated scripts, or web crawlers free of charge and without conditions"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Self-insured plans could let a contracted party, such as their administrator, post one combined in-network rate file per provider network that covers several plans and plan sponsors.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "I.B.3. Transparency in Coverage--Requirements for Public Disclosure",
                        "excerpt": "In new paragraph (b)(5)(iii), the Departments propose to permit self-insured group health plans under certain circumstances to allow another party, such as a service provider, with which they have an agreement as described in paragraph (b)(5)(ii), to make available in a single In-network Rate File"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The public price file changes would apply 12 months after a final rule is published. Until then, the current rules continue to apply.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "III.C.12. Applicability",
                        "excerpt": "apply 12 months following the date of publication of the final regulations in the Federal Register"
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(c)(1)(ii)",
                        "excerpt": "Until such time, the current provisions of paragraph (b) of this section continue to apply."
                    }
                ]
            }
        ],
        "who_is_affected": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The proposal covers non-grandfathered group health plans and health insurers offering non-grandfathered group and individual coverage.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "SUMMARY",
                        "excerpt": "regarding price transparency reporting requirements for non-grandfathered group health plans and health insurance issuers offering non-grandfathered group and individual health insurance coverage"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "Grandfathered plans are subject to the No Surprises Act price comparison tool requirement, so the phone and price comparison tool provisions reach them as well.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Footnote 25",
                        "excerpt": "section 9819 of the Code, section 719 of ERISA, and section 2799A-4 of the PHS Act do apply to grandfathered health plans and issuers offering grandfathered health insurance coverage."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "A fully insured plan meets the public disclosure duty if its insurer agrees in writing to provide the information.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(b)(5)(i)",
                        "excerpt": "To the extent coverage under a group health plan consists of group health insurance coverage, the plan satisfies the requirements of this paragraph (b) if the plan requires the health insurance issuer offering the coverage to provide the information pursuant to a written agreement."
                    }
                ]
            },
            {
                "kind": "inference",
                "kind_label": "Our analysis",
                "text": "Employers with self-insured plans are the employers most directly involved. The agencies expect these plans to rely on third-party administrators to carry out the changes.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "IV.C. ICRs Regarding Requirements for Disclosures to Participants, Beneficiaries, or Enrollees",
                        "excerpt": "the Departments assume that self-insured group health plans would depend on TPAs, including issuers providing administrative services only and non-issuer TPAs, to implement these proposed updates, including the new phone disclosure requirement."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The proposed footer link requirement applies to the plan's or insurer's website, not to an employer's own website.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "III.C.9. Required Method and Format for Disclosing Information to the Public",
                        "excerpt": "This requirement applies to a public website maintained by the plan or issuer and does not apply to a public website maintained by an employer or plan sponsor."
                    }
                ]
            }
        ],
        "business_implications": [
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The agencies estimate one-time costs of about 6.7 million hours and $913.7 million across all plans and insurers. After that, they estimate about 1.4 million hours and $68.2 million a year.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "IV.F. Summary of Ongoing and One-Time Burden Estimates for the Proposed Requirements",
                        "excerpt": "In addition, these proposed requirements are expected to impose one-time implementation costs, totaling approximately 6.7 million hours and $913.7 million across all plans (TPAs on behalf of plans) and issuers."
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "IV.F. Summary of Ongoing and One-Time Burden Estimates for the Proposed Requirements",
                        "excerpt": "In subsequent years, the burden is estimated at about 1.4 million hours and $68.2 million per year."
                    }
                ]
            },
            {
                "kind": "inference",
                "kind_label": "Our analysis",
                "text": "For a self-insured plan, enrollment counts for each coverage option would appear in public price files.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(b)(1)(i)(E)",
                        "excerpt": "Current numerical enrollment totals, as of the date the file is posted, for each coverage option offered by a group health plan or health insurance issuer that uses such provider network."
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "The agencies say network-level files would make it easier for employers to compare negotiated rates across networks when choosing which plans to offer.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "III.C.1.b. Other Improvements for File Users",
                        "excerpt": "organizing In-network Rate Files by network would 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"
                    }
                ]
            },
            {
                "kind": "fact",
                "kind_label": "From the source",
                "text": "A self-insured plan that hands the disclosure work to an administrator still violates the rule if the administrator fails to comply.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(b)(5)(ii)",
                        "excerpt": "if a plan or issuer chooses to enter into such an agreement and the party with which it contracts fails to provide the information in compliance with this paragraph (b), the plan or issuer violates the transparency disclosure requirements of this paragraph (b)."
                    }
                ]
            }
        ],
        "required_actions": [],
        "recommended_actions": [
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider submitting comments, for example on how the product type, enrollment count and phone provisions would work for your plan.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/02/25/2026-03798/private-health-insurance-transparency-in-coverage-extension-of-comment-period",
                        "locator": "DATES",
                        "excerpt": "The comment period for the December 23, 2025 proposed rule (90 FR 60432) is extended to March 2, 2026."
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "If you sponsor a self-insured plan, consider asking your third-party administrator how it would produce network-level files, the new context files and phone cost estimates if the proposal is finalized.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "IV.C. ICRs Regarding Requirements for Disclosures to Participants, Beneficiaries, or Enrollees",
                        "excerpt": "the Departments assume that self-insured group health plans would depend on TPAs, including issuers providing administrative services only and non-issuer TPAs, to implement these proposed updates, including the new phone disclosure requirement."
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider reviewing your written agreements with your insurer or administrator to see who is responsible for the price disclosures, since a self-insured plan remains liable if its contractor fails.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(b)(5)(ii)",
                        "excerpt": "if a plan or issuer chooses to enter into such an agreement and the party with which it contracts fails to provide the information in compliance with this paragraph (b), the plan or issuer violates the transparency disclosure requirements of this paragraph (b)."
                    }
                ]
            },
            {
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "text": "Consider confirming that the customer assistance number on your plan identification cards could handle requests for cost-sharing estimates.",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A2(b)(2)(iii)",
                        "excerpt": "Information provided under this paragraph (b) must be made available at the request of the participant or beneficiary via a telephone number through which a consumer may seek customer assistance that ERISA section 716(e) requires be indicated on any physical or electronic plan or insurance identification card"
                    }
                ]
            }
        ],
        "required_actions_assessment": {
            "state": "assessed",
            "text": "This is a proposed rule, so it creates no new requirement for employers or plans. Its changes would apply only if finalized, and until then the current Transparency in Coverage rules continue to apply."
        },
        "applicability": [
            {
                "criterion": "where",
                "label": "Where",
                "answer": "United States, nationwide",
                "kind": "fact",
                "kind_label": "From the source",
                "evidence": []
            },
            {
                "criterion": "employer_type",
                "label": "Employers",
                "answer": "Employers that sponsor group health plans: private employers, churches with certain plans, and state and local governments, with the duties falling on the plan and its insurer or administrator.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "II.C. Statutory Background for Enforcement",
                        "excerpt": "The Departments of Labor and the Treasury generally have primary enforcement authority over private sector employment-based group health plans. The Internal Revenue Service (IRS) has jurisdiction over certain church plans. HHS also has primary enforcement authority over non-Federal governmental plans, such as those sponsored by state and local government employers."
                    }
                ]
            },
            {
                "criterion": "size",
                "label": "Size",
                "answer": "The proposed regulatory text sets no size threshold and is written for any group health plan or health insurer.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Proposed 29 CFR 2590.715-2715A3(b)",
                        "excerpt": "A group health plan or health insurance issuer must make available on an internet website the information required under paragraphs (b)(1) and (2) of this section in machine-readable files"
                    }
                ]
            },
            {
                "criterion": "industries",
                "label": "Industries",
                "answer": "All industries whose employers sponsor group health plans, with health insurers and plan administrators most directly affected.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "IV.C. ICRs Regarding Requirements for Disclosures to Participants, Beneficiaries, or Enrollees",
                        "excerpt": "Accordingly, the Departments use issuers and TPAs as the unit of analysis for estimating the cost of proposed changes."
                    }
                ]
            },
            {
                "criterion": "functions",
                "label": "Functions",
                "answer": "Benefits and legal and compliance teams, working with the plan's insurer or administrator.",
                "kind": "inference",
                "kind_label": "Our analysis",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "SUMMARY",
                        "excerpt": "regarding price transparency reporting requirements for non-grandfathered group health plans and health insurance issuers offering non-grandfathered group and individual health insurance coverage"
                    }
                ]
            },
            {
                "criterion": "applies_if",
                "label": "Applies if",
                "answer": "You sponsor a non-grandfathered group health plan, insured or self-insured. A grandfathered plan is reached only by the phone and price comparison tool provisions.",
                "kind": "fact",
                "kind_label": "From the source",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "SUMMARY",
                        "excerpt": "regarding price transparency reporting requirements for non-grandfathered group health plans and health insurance issuers offering non-grandfathered group and individual health insurance coverage"
                    },
                    {
                        "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                        "locator": "Footnote 25",
                        "excerpt": "section 9819 of the Code, section 719 of ERISA, and section 2799A-4 of the PHS Act do apply to grandfathered health plans and issuers offering grandfathered health insurance coverage."
                    }
                ]
            },
            {
                "criterion": "action",
                "label": "Action",
                "answer": "Review the proposal and consider commenting by March 2, 2026. No compliance step is required now.",
                "kind": "recommendation",
                "kind_label": "Our suggestion",
                "evidence": [
                    {
                        "source": "https://www.federalregister.gov/documents/2026/02/25/2026-03798/private-health-insurance-transparency-in-coverage-extension-of-comment-period",
                        "locator": "DATES",
                        "excerpt": "The comment period for the December 23, 2025 proposed rule (90 FR 60432) is extended to March 2, 2026."
                    }
                ]
            }
        ],
        "open_questions": [
            {
                "question": "Would the final rule require self-insured plans to report a product type, such as health maintenance organization or preferred provider organization?",
                "context": "The proposed text requires a product type for each coverage option, but the agencies ask whether these labels fit self-insured plans and whether extending the requirement to them is practical."
            },
            {
                "question": "Will the agencies require one file format for all price files?",
                "context": "The agencies say they are considering naming a single format in rulemaking or technical guidance, but this proposal makes no format change."
            },
            {
                "question": "Would the agencies set service standards for phone cost estimates, such as answer times?",
                "context": "The agencies ask for comment on phone service standards but do not propose any."
            },
            {
                "question": "How much would the new public price files cost plans and their administrators to produce?",
                "context": "This record does not cover section IV.D of the rule (paperwork burden estimates for the public disclosure files) or section VI.D.3 (its cost analysis of the public disclosure changes)."
            }
        ],
        "events": [
            {
                "event_type": "originating_action",
                "label": "Issued",
                "occurred_on": "2025-12-23",
                "summary": "Transparency in Coverage",
                "source": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage"
            },
            {
                "event_type": "extension",
                "label": "Extended",
                "occurred_on": "2026-02-25",
                "summary": "Private Health Insurance; Transparency in Coverage; Extension of Comment Period",
                "source": "https://www.federalregister.gov/documents/2026/02/25/2026-03798/private-health-insurance-transparency-in-coverage-extension-of-comment-period"
            }
        ],
        "corrections": [],
        "sources": [
            {
                "label": "Transparency in Coverage, 90 FR 60432 (December 23, 2025)",
                "publisher": "Federal Register",
                "role": "primary",
                "url": "https://www.federalregister.gov/documents/2025/12/23/2025-23693/transparency-in-coverage",
                "pdf_url": "https://www.govinfo.gov/content/pkg/FR-2025-12-23/pdf/2025-23693.pdf"
            },
            {
                "label": "Private Health Insurance; Transparency in Coverage; Extension of Comment Period, 91 FR 9212 (February 25, 2026)",
                "publisher": "Federal Register",
                "role": "amendment",
                "url": "https://www.federalregister.gov/documents/2026/02/25/2026-03798/private-health-insurance-transparency-in-coverage-extension-of-comment-period",
                "pdf_url": "https://www.govinfo.gov/content/pkg/FR-2026-02-25/pdf/2026-03798.pdf"
            }
        ]
    }
}