The Price Is Right? Final Transparency Rules Require More Accurate And Reliable Data

The Departments of Labor, Health and Human Services (“HHS”), and the Treasury have finalized a number of updates to the current Transparency in Coverage rules. In summary, plans and issuers will move to quarterly reporting and publish in-network rates as dollar amounts, with a senior official attesting to the accuracy of the data. Here is our take on what changes, what it means for plan sponsors and health insurance issuers, and what to do before the rules take effect, with some provisions coming online as early as January 1, 2027.

Overview

On October 6, 2026, the Departments of Labor, HHS, and the Treasury (collectively, the Departments) published another Transparency in Coverage Final Rule (“final rule”). The final rule implements Executive Order 14221 and largely follows the December 2025 proposal, with notable changes intended to reduce burden. It revises the Transparency in Coverage 2020 Final Rule (“2020 final rule”), including requirements related to the machine-readable