Employee Benefits Security Administration, Internal Revenue Service and Centers for Medicare & Medicaid Services finalize Transparency in Coverage changes for group health plans
As of our last check on November 3, 2026, this is final but not yet in effect. It takes effect December 7, 2026.
We check the Federal Register daily for later actions. We check federal court opinions for rulings on published rules weekly, on Mondays. A ruling can take time to reach us, so not finding one here does not mean there is none.
In short
- What changed
- The Department of Labor's Employee Benefits Security Administration, the Internal Revenue Service and the Centers for Medicare & Medicaid Services finalized changes to the Transparency in Coverage rules. Group health plans must now give cost-sharing estimates by phone, and their public price files are reorganized, posted quarterly instead of monthly, attested to, and supplemented by new utilization, taxonomy and contact files.
- Who's affected
- Employers that sponsor non-grandfathered group health plans, whether insured or self-insured, and the insurers and third-party administrators that run disclosures for them. Grandfathered plans are touched only by an option to meet a No Surprises Act requirement through these disclosures.
- What to do
- New and changed duties: offer cost-sharing estimates by phone and use the updated balance billing statement for plan years beginning on or after January 1, 2027; meet the reorganized in-network and out-of-network file rules, quarterly posting and attestation from March 6, 2027; and add the utilization, taxonomy and text files and the website footer link from September 6, 2027, with the first utilization file posted July 1, 2028. Confirm that your insurer or third-party administrator will handle each of these under a written agreement.
What changed
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From the sourceIII.B.2. New Required Method and Format
because providing the disclosures by telephone is newly required under these rules.
Also: 29 CFR 2590.715-2715A2(b)(2)(iii)
must be made available at the request of the participant or beneficiary via a telephone number indicated on any physical or electronic plan or insurance identification card
Plans and insurers must now provide cost-sharing estimates by phone, at the customer assistance number on the plan identification card. Phone disclosure was previously optional.
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From the sourceIII.B.1. Balance Billing Protection Statement
these final rules only amend the existing language to more accurately reflect consumers' rights under the No Surprises Act
The existing balance billing statement that accompanies cost-sharing estimates is amended to reflect the No Surprises Act.
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From the source29 CFR 2590.715-2715A2(c)(7)
satisfies the requirements set forth in Code section 9819, ERISA section 719, and PHS Act section 2799A-4.
Also: SUMMARY
including for grandfathered group health plans and health insurance issuers offering grandfathered group and individual health insurance coverage that are not otherwise subject to these final rules
Meeting the cost-sharing disclosure rules also satisfies the No Surprises Act price comparison requirement, including for grandfathered plans that are not otherwise subject to these rules.
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From the source29 CFR 2590.715-2715A3(b)(1)(i)
An in-network rate machine-readable file for each provider network maintained or contracted by a group health plan or health insurance issuer
Also: 29 CFR 2590.715-2715A3(b)(1)(i)(B)
The provider network identifier;
In-network rate files are now organized by provider network instead of by coverage option, and must name the network, give a network identifier, and list each coverage option's identifier and product type.
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From the source29 CFR 2590.715-2715A3(b)(1)(i)(F)
must exclude from each file under paragraph (b)(1)(i) of this section a provider and their negotiated rate (provider-rate combination) for an item or service if the plan or issuer determines it is unlikely that the provider would be reimbursed
Plans must leave out provider and rate combinations that are unlikely to be paid given the provider's specialty, based on their own claims rules.
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From the source29 CFR 2590.715-2715A3(b)(1)(i)(E)(1)
plans and issuers must report a percentage number, in lieu of a dollar amount
Where a contract pays a percentage of billed charges and no dollar amount can be set in advance, plans report a percentage instead of a dollar amount.
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From the sourceIII.C.6. Out-of-Network Allowed Amount Machine-Readable File
a proposal to lower the threshold for including claims from 20 to 11 different claims per item or service, a proposal to increase the reporting period from 90 days to 6 months
Also: III.C.6. Out-of-Network Allowed Amount Machine-Readable File
the Departments are finalizing these amendments as proposed.
Out-of-network allowed amount files are now reported by health insurance market, cover 6 months of claims starting 9 months before posting (was 90 days), and include items with at least 11 claims (was 20).
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From the sourceIII.C.11. Timing
quarterly rather than monthly, beginning on the first day of the calendar-year quarter following the applicability date under paragraph (c)(1)
Also: III.C.11. Timing
requiring files to be posted on the first day of each calendar-year quarter (January 1, April 1, July 1, and October 1).
In-network rate and allowed amount files move from monthly to quarterly posting, on January 1, April 1, July 1 and October 1. The prescription drug file stays monthly.
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From the source29 CFR 2590.715-2715A3(b)(1)(iv)(A)
Must attest the following: To the best of its knowledge and belief, this plan or issuer has included all applicable information in accordance with the requirements of 29 CFR 2590.715-2715A3
Each price file must carry an attestation that it is true, accurate and complete, and the name of a chief executive officer, president or designated senior official.
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From the source29 CFR 2590.715-2715A3(b)(2)
Required contextual files. A group health plan or health insurance issuer must make available in a machine-readable format:
New supporting files are required: a utilization file, a taxonomy file and a plain text contact file.
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From the source29 CFR 2590.715-2715A3(b)(3)(iii)
that is labeled ``Price Transparency'' or ``Transparency in Coverage''
Also: 29 CFR 2590.715-2715A3(b)(3)(ii)
must be publicly available and accessible to any person, automated script, or web crawler free of charge and without conditions
Also: 29 CFR 2590.715-2715A3(b)(3)(i)
must be available in a single, non-proprietary, open-standards format
Websites must carry a footer link labeled "Price Transparency" or "Transparency in Coverage", and the files must be open to people and automated tools without accounts or other barriers, in a single open format set by guidance.
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From the sourceIII.C.4. Enrollment Totals
the Departments are not finalizing the proposal to include numerical enrollment totals in the In-network Rate File.
Also: III.C.11. Timing
the Departments are not finalizing the proposal to require plans and issuers to make available a Change-log File for each In-network Rate File
Two proposals were dropped: enrollment totals in the in-network rate file, and a change-log file.
Who is affected
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From the sourceI.A. Purpose
non-grandfathered group health plans and health insurance issuers offering non-grandfathered group or individual health insurance coverage must comply
The rule covers non-grandfathered group health plans and health insurers offering non-grandfathered group or individual coverage.
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From the sourceIII.B.2. New Required Method and Format
rests with the group health plan or health insurance issuer offering coverage, even when the plan or issuer contracts with a service provider to perform certain functions on its behalf.
The duty to comply rests with the plan or insurer, even when a service provider does the work.
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From the source29 CFR 2590.715-2715A3(b)(5)(i)
then the issuer, but not the plan, violates the transparency disclosure requirements of this paragraph (b).
For an insured plan, if the plan sponsor has a written agreement making the insurer responsible and the insurer fails, the insurer, not the plan, is in violation.
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From the source29 CFR 2590.715-2715A3(b)(5)(ii)
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).
If a plan relies on another party, such as a third-party administrator, and that party fails, the plan is in violation.
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Our analysisIII.B.2. New Required Method and Format
the Departments assume that self-insured group health plans will rely on service providers to implement these requirements
Employers with self-insured plans carry the most direct exposure, since the agencies expect those plans to rely on service providers but the plan stays liable.
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From the sourceIII.C.1. Provider Network-Level Reporting
Plans without defined networks will still be required to publish Allowed Amount Files.
Plans without defined networks have no in-network rate file but must still publish allowed amount files.
What it means in practice
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From the sourceIII.B.2. New Required Method and Format
service providers operating on behalf of plans and issuers may incur costs associated with implementing these requirements and may recover those costs through administrative fees.
The agencies recognize that service providers may pass their costs to plans through administrative fees.
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From the source29 CFR 2590.715-2715A3(b)(1)(iv)(C)
May satisfy the requirements of paragraphs (b)(1)(iv)(A) and (B) of this section by entering into a written agreement under which another party (such as a third-party administrator) makes the attestation
A third-party administrator may make the attestation and name its own senior official, but only under a written agreement covering the disclosures.
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From the sourceIII.C.5. Excluded Provider Information
This may require contractual agreements between the parties to produce the required data in accordance with the required cadence.
Plans that use payment integrity vendors for specialty rules may need contracts with those vendors to produce the taxonomy data on schedule.
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From the source29 CFR 2590.715-2715A3(b)(5)(iii)
(including those offered by different plan sponsors with which that other party has an agreement) and across different health insurance markets
A self-insured plan's administrator may combine in-network rate data for many plan sponsors that share a provider network, across markets.
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From the sourceIII.B.2. New Required Method and Format
nothing in these final rules requires plans and issuers to build separate data systems or back-end infrastructure
The rule does not require separate data systems for the phone, paper and online disclosures.
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From the sourceIII.C.6.b. Increasing the Reporting Period
shortly after the publication of these final rules, the Departments intend to release Schema version 3.0
Technical specifications (Schema version 3.0) are expected shortly after publication and will shape how files are built.
What to do
AmendSignal analysis sorts these by whether this document changes them.
New or changed
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From the source29 CFR 2590.715-2715A2(b)(2)(iii)
must be made available at the request of the participant or beneficiary via a telephone number indicated on any physical or electronic plan or insurance identification card
Also: 29 CFR 2590.715-2715A2(b)(2)(iii)
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.
Group health plans must provide cost-sharing estimates by phone at the identification card customer assistance number, accurate and given at the time of the request. Plans may limit answers to no fewer than 20 providers per day and must tell the caller about that limit.
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From the source29 CFR 2590.715-2715A2(b)(1)(vii)(A)
A statement that the cost-sharing information provided pursuant to this paragraph (b)(1) does not account for potential additional amounts in situations where applicable State or Federal law allow
Also: III.B.1. Balance Billing Protection Statement
these final rules only amend the existing language to more accurately reflect consumers' rights under the No Surprises Act
Plans must use the amended balance billing statement with cost-sharing estimates.
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From the source29 CFR 2590.715-2715A3(b)(1)(i)
An in-network rate machine-readable file for each provider network maintained or contracted by a group health plan or health insurance issuer
Also: 29 CFR 2590.715-2715A3(b)(1)(i)(C)
the Employer Identification Number (EIN); and the product type
Plans must publish an in-network rate file for each provider network, with the network name, network identifier, and each coverage option's name, identifier (or Employer Identification Number) and product type.
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From the source29 CFR 2590.715-2715A3(b)(1)(i)(F)
must exclude from each file under paragraph (b)(1)(i) of this section a provider and their negotiated rate (provider-rate combination) for an item or service if the plan or issuer determines it is unlikely that the provider would be reimbursed
Plans must exclude provider and rate combinations unlikely to be paid given the provider's specialty under their internal claims rules.
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From the source29 CFR 2590.715-2715A3(b)(1)(ii)(C)
during the 6-month time period that begins 9 months prior to the publication date of the machine-readable file
Also: 29 CFR 2590.715-2715A3(b)(1)(ii)(C)
in connection with fewer than 11 different claims for payment of that item or service in a single health insurance market
Plans must publish an out-of-network allowed amount file for each health insurance market, covering the 6 months that begin 9 months before posting, leaving out items with fewer than 11 claims.
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From the source29 CFR 2590.715-2715A3(b)(4)(i)
must be updated and posted quarterly on the first day of each calendar-year quarter beginning with the first calendar-year quarter following the applicability date under paragraph (c)(1) of this section
In-network rate and allowed amount files must be updated and posted quarterly on the first day of each calendar quarter.
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From the source29 CFR 2590.715-2715A3(b)(1)(iv)(A)
Must attest the following: To the best of its knowledge and belief, this plan or issuer has included all applicable information in accordance with the requirements of 29 CFR 2590.715-2715A3
Also: 29 CFR 2590.715-2715A3(b)(1)(iv)(B)
Must encode the name of the plan's or issuer's chief executive officer, president, or senior official designated to oversee the encoding of true, accurate, and complete data
Each price file must include an attestation of accuracy and completeness and the name of the chief executive officer, president or designated senior official.
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From the source29 CFR 2590.715-2715A3(b)(2)(i)
A utilization file, for each in-network rate machine-readable file specified in paragraph (b)(1)(i) of this section, that includes, for the most recent plan year that ends at least 6 months prior to the date the utilization file is made available
Also: 29 CFR 2590.715-2715A3(b)(4)(iii)
The utilization machine-readable file required under paragraph (b)(2)(i) of this section must be posted beginning on July 1, 2028, and updated and posted on an annual basis thereafter
Plans must publish a utilization file for each in-network rate file, covering the most recent plan year that ended at least 6 months earlier, posted annually.
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From the source29 CFR 2590.715-2715A3(b)(2)(ii)
A taxonomy file, for each in-network rate machine-readable file prepared as specified in paragraph (b)(1)(i) of this section, which includes the group health plan's or health insurance issuer's internal provider taxonomy, or other internal rules
Also: 29 CFR 2590.715-2715A3(b)(4)(iv)
the taxonomy file is still required to be posted but not updated for that quarter
Plans must publish a taxonomy file for each in-network rate file showing the specialty rules used to deny payment, posted every quarter even when unchanged.
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From the source29 CFR 2590.715-2715A3(b)(2)(iii)
A plain text file in a .txt format in the root folder
Also: 29 CFR 2590.715-2715A3(b)(2)(iii)(C)
Point-of-contact information, including a monitored email address for an individual or group dedicated to receiving and responding to inquiries
Also: 29 CFR 2590.715-2715A3(b)(4)(v)
as soon as practicable but no later than 7 calendar days following a change in any of the information required under paragraph (b)(2)(iii) of this section
Plans must post a plain text file in the website root folder with the file locations and a monitored contact email, and update it within 7 calendar days of a change.
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From the source29 CFR 2590.715-2715A3(b)(3)(iii)
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
Also: 29 CFR 2590.715-2715A3(b)(3)(iii)
that is labeled ``Price Transparency'' or ``Transparency in Coverage''
The plan's website home page footer, and any page with a footer, must link to the file page with the label "Price Transparency" or "Transparency in Coverage".
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From the source29 CFR 2590.715-2715A3(b)(3)(ii)
must be publicly available and accessible to any person, automated script, or web crawler free of charge and without conditions
Also: 29 CFR 2590.715-2715A3(b)(3)(i)
must be available in a single, non-proprietary, open-standards format
Files must be open to any person, automated script or web crawler, free and without accounts, credentials or blocking, in a single open format set by guidance.
Already required
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From the source29 CFR 2590.715-2715A3(b)(4)(ii)
The prescription drug machine-readable file required by paragraph (b)(1)(iii) of this section must be updated monthly
Also: III.C.11. Timing
which would retain the requirement under current paragraph (b)(1)(iii)
The prescription drug file must still be updated monthly.
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From the source29 CFR 2590.715-2715A3(c)(1)(i)
Until the applicability date specified in paragraph (c)(1)(ii) of this section, plans and issuers are required to continue to comply with 29 CFR 2590.715-2715A3 revised as of July 1, 2025.
Until the new provisions apply, plans must keep complying with the current public disclosure rules.
Worth considering
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Our suggestion29 CFR 2590.715-2715A3(b)(5)(ii)
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).
Consider reviewing your agreements with your insurer or third-party administrator to confirm they cover the phone disclosures, reorganized files, new supporting files and attestation, since a plan stays liable if its third-party administrator fails.
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Our suggestion29 CFR 2590.715-2715A3(b)(1)(iv)(C)
May satisfy the requirements of paragraphs (b)(1)(iv)(A) and (B) of this section by entering into a written agreement under which another party (such as a third-party administrator) makes the attestation
Consider deciding who will attest to the files: a named senior official at your organization, or your third-party administrator under a written agreement.
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Our suggestion29 CFR 2590.715-2715A2(c)(1)
This section applies for plan years beginning on or after January 1, 2027.
Consider asking your administrator how its customer service line will handle phone cost-sharing requests for plan years starting on or after January 1, 2027.
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Our suggestion29 CFR 2590.715-2715A3(b)(3)(iv)
it must provide a link on its own public website to the location where the files are made publicly available.
If your plan has its own public website and the files are hosted by a service provider, consider confirming that your site links to the file location and, where required, carries the footer link.
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Our suggestionIII.B.2. New Required Method and Format
service providers operating on behalf of plans and issuers may incur costs associated with implementing these requirements and may recover those costs through administrative fees.
Consider budgeting for possible increases in administrative fees from service providers.
Open questions
The source leaves these open. We'll update this record if a later document answers them.
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How should plans report a provider network identifier when none exists, and how should layered or leased networks be shown?
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What file format and technical specifications will the guidance require, and when will Schema version 3.0 be final?
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What more do the agencies say about the utilization, taxonomy and text files, and why the change-log file was dropped?
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How much do the agencies expect these changes to cost plans and their service providers?
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Will the prescription drug file requirement change?
Related changes
History
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Transparency in Coverage Source (opens in a new tab)