What Transparency in Coverage Is
The ACA’s Transparency in Coverage (TiC) rules require health plans and insurers to make health care pricing information available to the public and to plan members. The goal is to make prices easier to see, compare and study.
The detailed rules were finalized in 2020, and the main requirements have been in effect since 2022. They were updated in October 2026.
Which Plans It Applies To
TiC generally applies to non-grandfathered group health plans, including fully insured, self-funded and level-funded plans, as well as non-grandfathered individual coverage. There’s no general exemption for small employers.
The Two Main Requirements
1. Public pricing files (machine-readable files)
Since July 2022, plans and insurers have published large data files, called machine-readable files (MRFs), showing:
- Negotiated rates with in-network providers
- Historical allowed amounts for out-of-network services
These files are publicly available, with no login required. They’re designed for computer analysis by researchers, developers, regulators and others, not for everyday reading.
A separate prescription drug pricing file is also part of the rules, but regulators are still developing its technical standards, so it isn’t in effect yet.
2. Cost-estimate tools for members
Plans must give enrolled members a way to estimate their own out-of-pocket costs for covered services, based on their plan, provider, deductible and cost sharing. This requirement phased in starting in 2023 and has covered all covered items and services since plan years beginning in 2024.
Many carriers already had cost estimators before these rules. The rules set standards for what those tools must include.
2026 Updates
The October 2026 rules update the existing requirements rather than creating new ones. Key changes, which phase in during 2027 and 2028, include:
- Quarterly updates: Pricing files move from monthly to quarterly updates, starting in 2027.
- More useful data: Files are reorganized, with added context about networks and pricing.
- Easier to find: Plans and insurers must add a “Price Transparency” or “Transparency in Coverage” link on their websites, pointing to the files.
- Phone access: Members can get personalized cost estimates by phone, in addition to online and paper options. This aligns TiC with similar requirements under the separate federal No Surprises Act, 2021 law.
What It Means for Employers
- Fully insured plans: The insurance carrier handles TiC requirements, including the pricing files and cost-estimate tools.
- Self-funded and level-funded plans: The employer, as plan sponsor, is responsible, and typically partners with its TPA, administrator, or level-funded carrier to meet the requirements.
For official details, see CMS’s Transparency in Coverage Final Rules fact sheet.
Important: This information is provided for general educational purposes and reflects the rules as of November 2026. It is not legal or tax advice. How these rules apply depends on each employer’s specific circumstances, so employers should review their situation with their own legal counsel, ERISA attorney, CPA or tax advisor.