Healthcare transparency: Nice in theory; practical data usage lags 

It’s been over three years since group health plan sponsors and issuers, in order to comply with the Transparency in Coverage final rule, began posting Machine-Readable Files that contain in-network negotiated charges for every medical item and service with providers in their networks, as well as out-of-network allowed amounts and billed charges. This data had previously been considered by insurers as proprietary and confidential, but the government recognized the need to make healthcare costs more transparent. The rule also requires group health plan sponsors and issuers to post files for negotiated rates and historical net prices for covered prescription drugs, but regulators have delayed that particular requirement .

But even though the data has been available to the public since July 2022, almost 70% of very large employers (5,000+ employees) responding to our 2025 Health Policy Survey report that they have yet to meaningfully use the data.

Impeding use is the sheer amount of data that was dropped on the internet all at once, but not all in one place. According to a recent report from the Congressional Review Service, users have faced significant challenges, including issues with:

• Data access such as errors in downloading files, expiring URLs, application programming interfaces, and data retrieval limitations
• Data size and format including large file sizes, large numbers of files, variations in file structure, and inconsistent data formatting
• Data integrity like inconsistent naming conventions and errors, inconsistent negotiated rate data, ghost or zombie rates, incomplete alternative payment model data reporting, and limited provider details

Collecting the data from the files, analyzing it, validating the files against the schema provided by CMS as well as real claims charges, and summarizing it for use are each major tasks that take time to do properly. In addition, some of these tasks require not just healthcare knowledge, but a background in data science techniques. And even for those who overcome the obstacles to obtain and manipulate the data, practical application can be limited without other data sources since utilization data is not included in the MRFs.

Currently, we believe that the MRF data is being used predominately by carriers and providers during contract negotiations, although plan sponsors are starting to explore how they might use the data. Based on Mercer’s own research and discussions with vendors providing MRF data, we understand that a certain portion of the available data is still inadequate – missing, unreasonable, or has some other issue – which makes it difficult to use the data at a national level, especially in the context of a medical RFP where traditionally the margins of error have been slim.

Agencies have been actively responding to President Trump’s recent executive order directing the departments to require disclosure of actual prices (not estimates); issue updated guidance or propose rules to standardize price information; and update enforcement policies.

In-network and out-of-network files. A new FAQ from the federal government is intended to address concerns regarding machine readable files by issuing Schema 2.0. This will implement revised technical requirements for the in-network and out-of-network MRFs. According to the FAQ, Schema 2.0 is expected to reduce file size by excluding duplicative data and unnecessary fields, while also providing updates to better contextualize the data. Additionally, they are considering rulemaking to further refine and improve upon the MRF requirements under the TiC Final Rules. Schema 2.0 should be released on GitHub by Oct. 1, 2025, with compliance required by Feb 2, 2026.

Prescription drug file. The Departments also issued a Request for Information related to the prescription drug MRF, seeking public input on the prescription drug price disclosure requirements. This includes information on existing prescription drug file data elements and general implementation issues, such as health plans’ ability to access necessary data for reporting, as well as state approaches and innovation.

Hospital transparency. On the hospital side, CMS has issued new guidance related to the hospital price transparency final rules. In an effort to strengthen the hospital requirements, the CMS guidance mandates that hospitals post the actual prices for items and services, rather than estimates. This guidance appears to be effective immediately.

CMS has also released its own RFI to gather public feedback on how to enhance hospital compliance and enforcement, ensuring that shared data is accurate and complete. It’s been reported that as few as one-fifth of hospitals are in full compliance with the rules.

In spite of all the issues for the healthcare industry in rolling out MRFs, the Trump administration’s signaled intent to promote universal access to clear and accurate healthcare prices is a sign that the data will continue to improve in scope and value. With improvements in compliance as well as the data itself, using the data for price comparisons should eventually become the rule rather than the exception.