On October 6, 2026, federal agencies finalized new requirements under the Transparency in Coverage (TiC) rules. These changes are intended to make healthcare pricing information more accurate, easier to access, and more useful for consumers.
The final rule updates how health plans publish healthcare pricing data, expands access to personalized cost estimates, and introduces new documentation and accuracy requirements.
Although insurance carriers and third-party administrators (TPAs) generally handle these responsibilities, employers should understand the changes and confirm that their vendors are prepared to meet the new requirements.
What Is Changing?
The final rule introduces several changes that will take effect in phases beginning in 2027.
- Cost Estimates Available by Phone
- Beginning with plan years starting on or after January 1, 2027, participants must be able to request personalized cost-sharing estimates by calling the customer service number on their insurance ID card. Online and paper options will also remain available.
- Plans may limit phone requests to 20 providers per day, provided callers are informed of the limit. Updated balance-billing disclosures will also be required.
- Updated Healthcare Pricing Files
- Insurance carriers and TPAs must reorganize and update the public pricing files they publish online.
- Beginning in 2027, in-network rate files and out-of-network allowed-amount files will generally be updated quarterly instead of monthly. The new requirements also establish standardized file formats and additional information to help users interpret the data.
- New Accuracy Attestations
- Beginning March 6, 2027, applicable pricing files must include an attestation confirming that the information is accurate and complete, along with the identity of a senior official.
- A TPA may provide the attestation on behalf of a self-funded plan under a written agreement. However, the plan sponsor retains ultimate responsibility for compliance.
- Additional Website Disclosures and Reporting
Additional requirements will be phased in throughout 2027 and 2028, including:
- October 1, 2027: First posting of a new file explaining provider specialties excluded from certain services, along with a text file containing links and contact information.
- September 6, 2027: Applicable websites must include a footer link labeled “Price Transparency” or “Transparency in Coverage.”
- December 1, 2027: Target date for the first posting under the updated prescription drug pricing file requirements, including the required attestation.
- July 1, 2028: First annual utilization file, identifying services paid for and the in-network providers who received payment.
Note: The dates above reflect the implementation schedule described in the final rule and related agency guidance. Employers should confirm applicable deadlines with their carrier, TPA, or compliance advisor.
Does This Apply to Your Health Plan?
The requirements generally apply to non-grandfathered group health plans of all sizes, whether fully insured or self-funded. There is no small-employer exemption.
Certain arrangements, including stand-alone dental and vision plans, health flexible spending accounts (FSAs), health reimbursement arrangements (HRAs), and retiree-only plans, are generally excluded from the Transparency in Coverage requirements described here.
Grandfathered plans are exempt from the machine-readable file requirements, but certain phone-based price comparison requirements still apply.
What Is the Employer’s Responsibility?
Your responsibilities depend in part on how your medical plan is funded.
- Fully insured plans – The insurance carrier generally handles the pricing files and cost-estimate tools. Under a written agreement that requires the carrier to comply with applicable requirements, liability may be shifted to the carrier.
- Self-funded plans – The TPA or another service provider generally manages the pricing files and cost-estimate tools. However, the employer-sponsored plan retains ultimate legal responsibility, even when these duties are delegated by contract.
For self-funded employers, reviewing vendor agreements, confirming implementation plans, and documenting ongoing oversight are especially important.
Action Items for Employers
To prepare for the changes, we recommend taking the following steps:
- Review your vendor agreements. Before your 2027 renewal, confirm that your carrier or TPA agreement addresses the updated requirements. Request an amendment if necessary.
- Confirm your vendor’s implementation plan. Ask your carrier or TPA how it will address the January 2027 phone requirement and the March and September 2027 implementation deadlines.
- Understand potential costs. Ask whether the additional files, disclosures, or phone-based services will result in new administrative fees.
- Communicate with HR and benefits teams. Ensure staff understand that participants can request cost estimates online, by phone, or through paper disclosures, as applicable.
- Establish a compliance review process. Beginning in 2027, periodically confirm that your vendor’s pricing files and required disclosures are current and available. For self-funded plans, retain written confirmations, emails, screenshots, and records of any corrective action requested.
Employers are not expected to manually review the underlying pricing files. Instead, the focus should be on confirming that the responsible vendor is meeting its obligations and documenting that oversight.
What Happens if a Plan Does Not Comply?
Noncompliance may result in regulatory enforcement, corrective action, and potential financial penalties. The final rule reinforces the importance of accurate reporting and makes vendor oversight particularly important for self-funded plans.
How BSI Can Help
Understanding regulatory changes is an important part of managing your employee benefits program. Working with your benefits consultant can help you identify questions to raise with your carrier or TPA, review contractual responsibilities, and establish a process for monitoring compliance.
This material is provided for general educational purposes only and is not intended to constitute legal or tax advice. Requirements and implementation dates may change as additional guidance becomes available. Employers should consult their benefits advisor and legal counsel regarding their specific obligations.