The Departments of the Treasury, Internal Revenue Service (IRS), Health and Human Services (HHS) and Labor (DOL) (together, the Departments) published proposed rules on December 23, 2025 (Proposed Rule), aimed at improving the standardization, accuracy, and accessibility of the pricing information disclosed in the machine readable files (MRFs) mandated under the Transparency in Coverage (TiC) rules (background on the TiC rules and the MRFs can be found in our article here). The Proposed Rule aligns with Executive Order 14221's directive to the Departments to increase standardization of pricing disclosure information, to ease comparison of pricing disclosure information between health plans, and ensure such data is accurate and meaningful. The comment period for the Proposed Rule closes on February 23, 2026, and the Departments also have indicated that the requirements would not take effect until a year after publication of the final rule.

Material provisions of the Proposed Rule include:

• Excluding items and services from in-network MRF data for a provider if the plan or issuer determines it is unlikely that the provider would be reimbursed for such item or service given the provider's area of specialty (eliminating what is known as "ghost rates").
• Having third party administrators (TPAs) and issuers create a separate file for each provider network they maintain, allowing that network provider file to be leveraged for all plans and policies using the network, including...

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