Employers sponsoring non-grandfathered, self-funded group health plans and health insurance issuers remain responsible for the ongoing Transparency in Coverage (TiC) public posting requirements. Plans must publicly post machine-readable files (MRFs) that disclose in-network negotiated rates, out-of-network allowed amounts, and billed charges for covered items and services.
For fully insured coverage, the group health plan satisfies the TiC MRF posting requirement if the plan requires the health insurance issuer to provide the required MRF information.
These MRFs must be updated monthly. While updates are not required on a specific day of the month, they must be made at 30-day intervals. The TiC rules do not require retention of prior months’ files, but the Departments of Labor and Health and Human Services, and the Internal Revenue Service (the “Departments”) recommend maintaining prior months’ MRFs to help demonstrate compliance.
The Departments released schema version 2.0 on Oct. 1, 2025, and beginning Feb. 2, 2026, will assess compliance for the in-network and out-of-network MRFs using schema v2.0.
The TiC rule also contemplates a prescription drug MRF (negotiated rates and historical net prices), and the Departments have indicated they intend to develop technical requirements and an implementation timeline. In 2025, the Departments issued a formal Request for Information (RFI) on the prescription drug MRF requirement, signaling continued activity in this area.
Employer Action Items
- Confirm whether the group health plan is non-grandfathered.
- Self-funded plans can contract with a third-party administrator (TPA) or other vendor to generate and host the MRFs, but if the vendor fails to post compliant files, the plan sponsor remains responsible.
- Fully insured plans should confirm that a written agreement is in place requiring the health insurance issuer to post the MRFs. If the issuer fails under that agreement, the issuer (not the plan) violates the TiC MRF posting requirement.
- Ensure the MRFs are publicly accessible, free of charge, and not gated (no account creation, password, credentials, or personally identifiable information required).
- If a TPA or vendor hosts the files on a third-party site, confirm that the employer’s or plan’s public website includes a link to the file location.
- Confirm that the posting clearly shows the “most recently updated” date and that the files are updated monthly (at approximately 30-day intervals).