Regulatory changes

Health plan price files go quarterly, and members get a phone option in 2027

A final rule published on 6 October 2026 moves the health plan price files from monthly to quarterly, lowers the out-of-network reporting threshold from 20 claims to 11, and adds a phone option for cost estimates. Most changes start in 2027.

The applicable.ai team4 min read

Almost every organization with employees has a stake in this one. On 6 October 2026, the Treasury, Labor and Health and Human Services departments published final amendments to the Transparency in Coverage rules (91 FR 63748). These are the rules that make health plans post what they pay providers in large public files, and give members a tool to estimate their own costs before they get care.

The rules take effect on 7 December 2026, but most of the work they require starts later.

Who it covers

The rules apply to "non-grandfathered group health plans and health insurance issuers offering non-grandfathered group or individual health insurance coverage." Grandfathered plans are generally outside them. If your organization offers a group health plan, it's probably covered, even though an insurer or administrator usually does the actual posting. That second part is easy to forget, and it matters, because the obligation sits with the plan.

What changes in the price files

The rules have required plans to post machine-readable files of in-network rates and out-of-network allowed amounts every month. Under the amendments, plans will "update and post the In-network Rate and Out-of-network Allowed Amount Files quarterly rather than monthly."

A few other changes come with that:

  • Plans will prepare "one In-network Rate File for each provider network they maintain or contract with, rather than for each plan or policy they offer." Many plans share a network, so this should cut down on duplicate files.
  • The claims threshold for reporting out-of-network allowed amounts drops "from 20 to 11 claims," and the reporting period becomes "more than twice as long." More out-of-network prices should show up as a result.
  • Rates for "unlikely provider-to-service mappings" come out of the in-network files, and plans must post the internal provider taxonomy mapping or other rules they used to prepare each In-network Rate File.
  • A new file, posted alongside each In-network Rate File, lists providers who "have submitted and received reimbursement for at least one claim" for a covered item or service.
  • Plans must publish a plain text file in the root folder of their website with contact information for the files, plus a footer with website URLs.
  • Each file must carry a statement from the plan that "the information encoded is true, accurate, and complete as of the date in the file."

A phone option for members

Cost-sharing estimates that plans already give through an online tool, or on paper on request, must "also be made available over the phone, upon request." A plan may limit requests, but to no fewer than 20 providers per day. For grandfathered plans that aren't otherwise covered, the departments say meeting the phone requirement also satisfies section 114 of the No Surprises Act.

When it applies

There are three dates to track, according to the CMS fact sheet:

ChangeApplies
In-network Rate and Allowed Amount file changesFive months after publication
The taxonomy file, the new provider claims file and the text file11 months after publication
Self-service tool changes, including the phone optionPlan years beginning on or after 1 January 2027

The departments expect a net saving to plans and issuers of "approximately $174.5 million annually," starting in the second year.

What it could mean

For most employers this is a question for a vendor. Your insurer or third-party administrator will rebuild the files. Still, we think it's worth an email to them this quarter, for two reasons.

The first is the phone requirement. It lands at the start of the 2027 plan year for most calendar-year plans, which is close. Somebody's call center has to handle cost-estimate requests, and if your plan's contract is silent on that, now is the time to find out whose it is.

The second is that accuracy statement. Plans will be saying that the files are "true, accurate, and complete." If your vendor posts the files for a self-funded plan, check what your contract says about accuracy and who stands behind it. We'd guess most contracts written before this rule don't say much.

Our view on the files themselves: quarterly updates with fewer duplicates are a sensible trade. The monthly files were huge and, for most people, unusable. The lower out-of-network threshold is the change we'd watch. Our guess is that thin out-of-network data put off a lot of people who tried to use it, and nearly halving the threshold should help.

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