The 2026 Transparency in Coverage rule: what changes for self-funded employers

Since 2022, group health plans and insurers have had to publish machine-readable files listing the rates they negotiate with in-network providers and the amounts they allow for out-of-network care. The files were huge, hard to find and hard to use. The final rule the Departments of Labor, HHS and the Treasury published on October 6, 2026 rewrites how those files are built, how often they are posted and who vouches for them.

It applies to non-grandfathered group health plans, including self-funded plans, and to insurers. If your company self-funds its plan, the carrier or third-party administrator (TPA) running it almost certainly builds and posts the files today. Under the rule, the plan is still the party responsible for them.

What changes in the files

• Quarterly, not monthly. The in-network rate and out-of-network allowed amount files are updated and posted on the first day of each calendar quarter. The first quarterly posting under the new rules is April 1, 2027.
• Organized by network. In-network rate files gain the product type (such as HMO or PPO), the provider network name and a network identifier. A TPA can publish one file per provider network that covers every plan using that network.
• Fewer impossible rows. Plans may leave out rates for provider and service combinations that would not happen in practice, such as a dermatologist billing for heart surgery, based on their internal provider taxonomy. That taxonomy is published in its own file.
• More out-of-network data. The allowed amount file now covers a 6-month period that begins 9 months before posting (it was 90 days within a 180-day lookback), and the minimum claims count for an item or service drops from 20 to 11 in a single market.
• A named person behind the data. Each file must carry an attestation that the information is true, accurate and complete, plus the name of a CEO, president or designated senior official. See who attests for a self-funded plan.

New files and links

• Text file. A plain .txt file in the root folder of the plan's or TPA's website pointing to the files, with a monitored email address for questions. It must be updated within 7 days of any change.
• Footer link. A link labeled "Price Transparency" or "Transparency in Coverage" in the website footer, going straight to the page that hosts the files. If the TPA hosts the files and the plan has its own public website, the plan must link to them from that site.
• Taxonomy file, posted quarterly, and a utilization file listing the services and providers that were actually paid, posted once a year starting July 1, 2028.
• Prices by phone. For plan years beginning on or after January 1, 2027, the cost information members can already get online or on paper must also be available by phone.

The dates for each piece are laid out in the key dates guide.

What to ask your TPA or carrier now

• Which provider networks will our files be published under, and under what network names?
• Who will make the attestation for our plan, and is that set out in a written agreement?
• Where will the text file and footer link live, and does our own website need a link?
• Who monitors the contact email, and how fast do they answer?
• Will we see the files before they are posted on April 1, 2027?

The part that saves money

Compliance is the obligation; the data is the opportunity. Hospitals already publish what each insurer pays them, service by service. For a self-funded plan, that shows which nearby hospitals cost the plan more for the same MRI or lab panel under your own carrier, which is useful for steering, network design and the renewal conversation.