The "Transparency in Coverage" (TiC) landscape is evolving. In December 2025, CMS released a proposed rule (CMS-9882-P) aimed at making pricing data more manageable for data consumers and more meaningful for members. We’ve analyzed the proposal and submitted formal comments to ensure the next generation of transparency tools works for everyone.

The Basics: What’s Changing?

The proposed rule focuses on reducing "data bloat" and technical friction:

• Quarterly Updates: Moving from monthly to quarterly reporting for Machine-Readable Files (MRFs).
• Network-Level Reporting: Instead of generating filers per plan, data will be organized by provider network with a new 
• Eliminating "Ghost Rates": Plans would be required to strip out rate data for services a provider is unlikely to perform (e.g., a podiatrist’s rate for heart surgery), making files smaller and more accurate.
• Better Findability: New requirements for a plain text (.txt) file in the root folder and a footer link on the home page for automated discovery.
• OON Threshold: Reducing the OON claims threshold from 20 to 11 with new aggregating requirements to ensure more pricing is visible. 
• Alignment of Disclosure Requirements: Updated requirements to ensure real time phone based cost estimates are available along with notices related to new balance billing requirements.

Sharing price transparency over the phone and upon request has a proposed effective date of January 1, 2027.  The remaining proposed changes would not be effective until 12 months after the the rule is finalized and published on the Federal Register.

Kyruus Health’s Takeaways & Recommendations

In our comments to CMS, we focused on moving the industry toward true financial certainty rather than just raw data.

1. Moving from "Codes" to "Episodes"

Current rules focus on billing codes, but patients shop for health events (like a knee replacement or having a baby). We urged CMS to:

• Support Episode-Based Pricing: We highlighted our Care Plans model, which bundles services into a single estimate, as a better way to mirror the actual patient experience.
• Finalize the Advanced EOB (AEOB): We’re pushing for the AEOB to become the standard, moving the industry from "estimated ranges" to towards quotes for members before they seek care.

2. Quality Over Quantity in Data Cleaning

While we support removing "Ghost Rates," we cautioned CMS against a "one-size-fits-all" technical approach:

• Flexibility is Key: We recommended that plans be allowed to use third-party clinical logic (like Kyruus’ taxonomy) to filter irrelevant rates, rather than relying solely on claims systems.

3. A Unified Standard for Payers and Hospitals

Discrepancies between payer data and hospital data cause confusion. We advocated for a Consolidated Negotiated Rate Schema to align both sides, making it easier for members to compare costs and for plans to maintain data integrity.

In summary, We believe the next iteration of TIC should prioritize two goals: enhancing the member experience and reducing administrative burden. By filtering out data 'noise' and shifting toward patient-centered 'episodes,' we can finally provide the financial clarity members demand. We strongly encourage your organization to submit comments on the proposed rule to help shape this transition.