Trump Administration Proposes Significant Updates to Health Care Disclosure Requirements

With the objective of making health care prices clear, accurate, and actionable for Americans, the Administration has teamed up the Centers for Medicare & Medicaid Services (CMS) with the DOL and the Department of the Treasury to propose significant updates to the rules governing healthcare price transparency. According to Health and Human Services Secretary Robert F. Kennedy, Jr., “This proposal delivers real transparency by turning hidden pricing into clear, usable information—so families can make informed decisions and hold the system accountable.

The primary improvements are the following (from the CMS website):

  • Requiring plans and issuers to exclude from the In-network Rate Files certain data for services providers would be unlikely to perform.

  • Reorganizing In-network Rate Files by provider network rather than by plan, cutting redundancy, and aligning with how most hospitals report data pursuant to the Hospital Price Transparency requirements.

  • Requiring Change-log and Utilization Files so users can easily identify what has changed from one In-network Rate File to the next and have clear information on which in-network providers are actively furnishing which items and services.

  • Reducing reporting cadence for In-network Rate and Allowed Amount Files from monthly to quarterly, significantly reducing burden while maintaining meaningful transparency.

  • Increasing the amount of out-of-network pricing information reported by reorganizing Allowed Amount files by health insurance market type, reducing the claims threshold to 11 or more claims, and increasing the reporting period from 90 days to 6 months and the lookback period of data from 180 days to 9 months. The proposed rule is on the CMS website at https://www.federalregister.gov/public-inspection/2025-23693/transparency-in-coverage; CMS has also published fact sheet, which is at http://cms.gov/newsroom/fact-sheets/transparency-coverage-proposed-rule-cms-9882-p.

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