Who attests to a self-funded plan's price files: your TPA, but you're still on the hook

Starting with the files that apply from March 6, 2027, every Transparency in Coverage price file has to say who stands behind it. The in-network rate file, the out-of-network allowed amount file, the prescription drug file and the new taxonomy and utilization files each must include two things.

What each file must carry

• An attestation that, to the best of the plan's or issuer's knowledge and belief, it has included all applicable information and the information is true, accurate and complete as of the date in the file.
• A name: the chief executive officer, president or a senior official designated to oversee the encoding of true, accurate and complete data.

Can the TPA do it?

Yes, with conditions. A plan may meet the requirement through a written agreement under which another party, such as a third-party administrator, makes the attestation on the plan's behalf and encodes the name of its own CEO, president or designated senior official. The rule allows this only where the plan has an agreement for that party to provide the file information under the rule's special rules for shared files, which is how most TPAs already publish one file for many self-funded plans.

So for most self-funded employers, the name in the file will be someone at the TPA or carrier, not one of your executives. That does not move the obligation. The requirement sits with the plan; the agreement is the way it is met.

What a plan sponsor should check

• The services agreement with your TPA or carrier covers the Transparency in Coverage files, including the attestation, the text file and the website link.
• The files your plan appears in are posted on time each quarter, starting April 1, 2027.
• The files are reachable without a login, form or blocked download.
• The attestation and the official's name are actually present in the files.
• Your plan's own website links to the files if the TPA hosts them.

None of this requires reading a multi-gigabyte file by hand, but someone should look. The dates for each requirement are in the key dates guide, and the full list of changes is in the rule overview.

Hospitals went first

Hospitals have had a similar requirement in their own price files since 2026: a named official attesting to the file. Those hospital files also list what each insurer pays the hospital, service by service, which a self-funded plan can use to check what its own carrier pays nearby.