The Departments of Health and Human Services, Labor, and the Treasury have proposed updates to the Transparency in Coverage (TiC) machine-readable file requirements under CMS-9882-P.

Gigasheet submitted formal comments grounded in direct operational experience. Since the Transparency in Coverage rules took effect in 2021 and 2022, we have ingested and analyzed payer and hospital machine-readable files nationwide. Processing negotiated rate data at scale provides a clear view into both the strengths of the framework and the practical limitations that reduce its usability.

Overall, we support the direction of the proposed rule. The changes move Transparency in Coverage from raw disclosure toward usable market infrastructure.

What Is CMS-9882-P?

CMS-9882-P is a proposed update to the Transparency in Coverage rule governing how health insurers publish machine-readable files of negotiated rates.

The proposal focuses on improving comparability, data integrity, and analytic usability of in-network rate files. All topics we enthusiastically support!

Standardized Provider Network Names Improve Comparability

Today, provider network identifiers vary significantly across issuers. Similar networks may appear under different labels, while distinct file names do not always represent economically distinct networks.

This makes cross-payer comparisons difficult and increases the normalization burden for analysts, employers, and providers attempting to benchmark rates.

We strongly support standardized provider network name disclosure. Uniform network attributes will materially improve like-for-like comparisons across carriers.

We did identify one implementation risk. Payers could technically comply while fragmenting networks through micro-tiering or narrow geographic segmentation. Excessive segmentation could reduce comparability without violating disclosure requirements. Guardrails around allowable network definitions would help preserve the rule’s intent.

Removing Implausible Negotiated Rates Strengthens Data Integrity

Current machine-readable files contain negotiated rate entries that are operationally impossible (aka “zombie rates”). These include services reported in invalid places of service or providers listing rates for procedures they could not plausibly perform.

Downstream users must build validation pipelines to detect and remove this noise. This adds cost and complexity while increasing the risk of analytic distortion.

Requiring the exclusion of clinically implausible or invalid negotiated rates at the source will significantly improve reliability and reduce processing burden.

Clear definitions will be essential. If “implausible” is not well defined, rare but legitimate negotiated rates could be excluded. Precision in regulatory language will protect both accuracy and transparency.

Utilization Data Transforms Price Transparency into Actionable Intelligence

The proposed inclusion of utilization data is the most impactful update in CMS-9882-P. Today, price transparency without volume context can feel like a map without a scale, which is why we combine price transparency data with historic claims data utilization benchmarks. We do this to avoid rare services and outlier negotiated rates that often distort averages, creating the illusion of economic significance where financial exposure is actually minimal.

By integrating utilization data, negotiated rates can finally be weighted by actual frequency (vs extrapolications from claims data). This transforms 'static price disclosure' into 'decision-grade analytics,' allowing employers to target high-spend services and helping providers benchmark meaningful market variations. While 2027 feels distant, the structural shift from Price to Price x Volume requires a total rethink of data infrastructure, a challenge we’ve already solved at Gigasheet.

Taxonomy Reporting and NPI Alignment Require Clarity

The proposal includes additional provider taxonomy reporting.

However, specialty taxonomy already exists in the National Provider Identifier registry maintained by CMS. This creates a practical question: if payer-reported taxonomy conflicts with the NPI registry, which source should be treated as authoritative?

Clear guidance on reconciliation standards will help maintain cross-payer comparability and reduce downstream interpretation inconsistencies.

Quarterly Updates Improve Data Quality

We support the shift from monthly to quarterly updates.

Producing accurate machine-readable files at national scale requires validation, coordination, and internal review. A quarterly cadence improves consistency and reduces error rates.

Reliable data is more valuable than frequent but inconsistent updates.

Standardized MRF Discovery Would Reduce Technical Friction

Today, each payer publishes machine-readable files through its own portal or webpage structure. There is no standardized URL pattern for locating table-of-contents files.

This increases engineering overhead and limits automation.

A standardized discovery convention, even a minimal one, would reduce ingestion friction and lower technical barriers for analytics firms and market participants relying on this data.

Does CMS-9882-P Improve Transparency?

Yes.

Standardized network identifiers improve comparability. Removal of implausible rates improves integrity. Utilization data improves analytic precision. Quarterly updates improve reliability.

Collectively, these changes strengthen the practical usability of Transparency in Coverage data for providers, payers, employers, and consultants.

Why This Matters for the Healthcare Market

Transparency in Coverage data now influences provider contract negotiations, employer benefit strategy, and competitive intelligence across markets.

When negotiated rate data becomes more comparable and contextualized, negotiations become more evidence-driven. Market inefficiencies become measurable rather than anecdotal.

Transparency is effective when the data functions as credible market infrastructure. CMS-9882-P represents a meaningful step in that direction.

Transparency in Coverage Proposed Rule: Key Questions & Answers

What is CMS-9882-P?

CMS-9882-P is the proposed rule updating the Transparency in Coverage requirements for machine-readable files published by health insurers, particularly in-network negotiated rate reporting.

What are Transparency in Coverage machine-readable files?

Transparency in Coverage machine-readable files are publicly posted datasets that disclose negotiated rates between health insurers and providers at the billing code and NPI level.

Why is utilization data important in price transparency?

Utilization data shows how frequently services are performed (i.e., volume) within a payer population. Without utilization context, averages and medians can be misleading because rare services may distort results.

Why are standardized network names necessary?

Standardized network identifiers allow analysts and employers to make accurate cross-payer comparisons and avoid ambiguity created by inconsistent labeling.

How does the proposed rule improve negotiated rate reporting?

The proposal improves reporting by removing clinically implausible rates, standardizing network disclosure, adding utilization data, and moving to quarterly updates to improve quality and reliability.

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