Melissa Dehoff • December 23, 2025

Proposed Rule Includes Updates to Disclosure Requirements to Health Care Transparency Rules

Author

Melissa Dehoff

Date

December 23, 2025

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The Centers for Medicare & Medicaid Services (CMS), in partnership with the Department of Labor and the Department of the Treasury (the Departments), included major updates to the health care price transparency rules established during President Trump’s first term in a proposed rule published in today’s Federal Register.

The proposed rule is in line with Executive Order 14221, which ensures health care pricing data is not only public but impactful and actionable.


Key improvements include:

  • Requiring plans and issuers to exclude from the In-network Rate Files certain data for services providers would be unlikely to perform.
  • Reorganizing In-network Rate Files by provider network rather than by plan, cutting redundancy, and aligning with how most hospitals report data pursuant to the Hospital Price Transparency requirements.
  • Requiring Change-log and Utilization Files so users can easily identify what has changed from one In-network Rate File to the next and have clear information on which in-network providers are actively furnishing which items and services.
  • Reducing reporting cadence for In-network Rate and Allowed Amount Files from monthly to quarterly, significantly reducing burden while maintaining meaningful transparency.
  • Increasing the amount of out-of-network pricing information reported by reorganizing Allowed Amount files by health insurance market type, reducing the claims threshold to 11 or more claims, and increasing the reporting period from 90 days to 6 months and the lookback period of data from 180 days to 9 months.


The Departments are proposing these changes to open the door for more organizations, including those with fewer technical resources, to analyze pricing data, build consumer-friendly tools, and drive competition across the health care industry.


Under the proposal, group health plans and health insurance issuers would be required to provide the same detailed cost-sharing information whether viewed online, or in print or provided by telephone, upon request. This modernization would ensure that transparency is not limited by internet access or digital literacy. Further, updated disclosures will take into account new federal protections against balance billing under the No Surprises Act. These disclosures would ensure patients understand their rights and potential financial responsibilities before they seek care.


Additional information is provided on the CMS fact sheet. Feedback and comments on the proposed rule will be accepted until February 23, 2026.

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