A Transparency in Coverage compliance program is the set of owners, procedures and checks a non-grandfathered group health plan, health insurance issuer or administrator uses to post price machine-readable files and give participants cost-sharing information under 45 CFR 147.212 and 147.211. A final rule published October 6, 2026 amends both sections, with changes that apply on staggered dates from January 1, 2027 to July 1, 2028. Integral Healthcare Solutions (IHS) drafts the data-owner map, vendor oversight and checks for your compliance team and counsel to adopt.
Last updated: November 2026. Regulation text read November 5, 2026.
What does Transparency in Coverage require of plans and issuers?
Two duties: post machine-readable files for the public, and give cost-sharing information to a participant who asks. Section 147.212(b), as in force now, says: "A group health plan or health insurance issuer must make available on an internet website the information required under paragraph (b)(1) of this section in three machine-readable files, in accordance with the method and format requirements described in paragraph (b)(2) of this section, and that are updated as required under paragraph (b)(3) of this section." The three files cover in-network rates, out-of-network allowed amounts and prescription drugs. Section 147.211(b) requires a plan or issuer, on request of a participant, beneficiary or enrollee, to provide the cost-sharing information listed in (b)(1) by the methods in (b)(2).
The sections do not apply to grandfathered health plans, to health reimbursement arrangements or other account-based group health plans, or to short-term limited-duration insurance. Parallel rules sit at 29 CFR 2590.715-2715A3 and 26 CFR 54.9815-2715A3; this page works from the 45 CFR text. Definitions are in 147.210; the amending rule is "Transparency in Coverage," Federal Register document 2026-20447.
What changes in the October 2026 final rule, and when does each change apply?
The final rule is effective December 7, 2026. That is not the date your plan must comply. The regulation text sets later applicability dates, and until each arrives the sections as revised October 1, 2025 stay in force.
| Change | Applies |
|---|---|
| Amended 147.211: phone method, preventive-service default, bundled-payment estimates, revised balance-billing statement | Plan years (policy years in the individual market) beginning on or after January 1, 2027 |
| Amended 147.212 generally: in-network rate file for each provider network, out-of-network file for each health insurance market, attestation, quarterly updates | March 6, 2027 |
| Contextual files (utilization, taxonomy, root-folder text file) and the website footer link | September 6, 2027 |
| First posting of the utilization file | July 1, 2028, then annually |
The parallel 26 CFR and 29 CFR amendments carry the same March 6 and September 6, 2027 dates. In practice:
- The in-network rate file moves to one file for each provider network the plan or issuer maintains or contracts, with the network name and identifier. A plan or issuer must also exclude a provider-rate combination when it is unlikely the provider would be reimbursed for that item or service given the provider's specialty under its internal taxonomy or other internal rules.
- The out-of-network allowed amount file is built for each health insurance market and covers a 6-month period that begins 9 months before publication. It omits an item or service when reporting would involve fewer than 11 different claims for it in a single market. The text in force now uses 90 days beginning 180 days before publication and a floor of fewer than 20 claims per provider under a single plan or coverage.
- Each file required by (b)(1)(i) through (iii) carries an attestation that, to the best of the plan's or issuer's knowledge and belief, all applicable information is included and the information is true, accurate and complete as of the date in the file, with the name of the chief executive officer, president or designated senior official encoded. An administrator can make the attestation under a written agreement, but only if the plan or issuer has an agreement with it under (b)(5).
- Timing is monthly under the text in force now. Under the amended section, the in-network and out-of-network files are updated quarterly on the first day of each calendar-year quarter beginning with the first quarter after March 6, 2027 (IHS's reading: April 1, 2027), the prescription drug file monthly, and (from September 6, 2027) the text file within 7 calendar days of a change.
Who needs it and what triggers it?
A non-grandfathered plan, an issuer, or the administrator that produces their files needs an owner for each file and each request channel. These triggers are IHS's reading, not an agency list.
- A plan or issuer has files and a consumer tool but no data-owner map for them.
- The plan is changing issuers or administrators and needs new written agreements.
- The customer-service phone line has no cost-sharing request procedure ready for plan years beginning January 1, 2027.
Who is on the hook when a vendor or issuer posts the files?
It depends on the arrangement. In amended 147.212(b)(5) (the same rule is in current (b)(4)), for insured coverage the text says that where an issuer and plan sponsor have a written agreement under which the issuer agrees to provide the information on behalf of the plan, and the issuer fails to do so, "then the issuer, but not the plan, violates the transparency disclosure requirements of this paragraph (b)." For other third parties it goes the other way: "if a plan or issuer chooses to enter into such an agreement and the party with which it contracts fails to provide the information in compliance with this paragraph (b), the plan or issuer violates the transparency disclosure requirements of this paragraph (b)." Which sentence fits your plan is a question for your counsel. Separately, a good-faith error or omission made with reasonable diligence is not a failure to comply by itself, provided the plan or issuer corrects it as soon as practicable.
How IHS helps
IHS runs a gap assessment of your current practices against 147.210 through 147.212 and the amended text with its applicability dates, maps the evidence you hold, and drafts what is missing: a data-owner map, a file procedure and calendar, vendor oversight procedures with a written-agreement checklist, a quarterly check of file availability, update date and links, a participant request workflow for the internet tool, paper and phone, and a change log keyed to each applicability date. IHS was founded in 2002 by Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC, and works across accreditation consulting, compliance services and program development. This build sits in our Compliance Services line.
Your plan or administrator supplies coverage option identifiers, network, rate and claims data, vendor contracts, and counsel. The limit: IHS does not generate machine-readable files or build the consumer tool; the plan or its vendor does. IHS drafts; you adopt and submit.
What to have ready
- A list of your plans and coverage options with the issuer or administrator for each, and whether each is grandfathered, account-based or insured.
- Your provider networks and the plans that use each, because the amended in-network file is per network.
- The web page that hosts your files, the owner of each file, and the date shown on each.
- Your written agreements with issuers, administrators and vendors.
- Who would sign the attestation and be named in the files.
- Your process for participant requests across the internet tool, paper and phone.
- The counsel who will confirm allocation of responsibility and contract terms.
If several are missing, book the free introductory call and bring what you have.
How does outside drafting support compare with other routes?
A plan can rely on its issuer or an administrator under a written agreement, buy software that produces the files, ask counsel to allocate responsibility, or add outside drafting support. Software produces files; procedures for who checks them still have to be written (IHS's inference). Counsel allocates responsibility, which IHS does not. IHS drafts the procedures and checks for your team to adopt and does not pick a route for you. For a general program build, see compliance program development.
What does it cost?
Authority fees: the sections we read state no fee for posting files or answering participant requests. IHS fees: IHS scopes each engagement after a free introductory call, and no IHS figure appears on this page. Scope moves with the number of plans, networks and vendors and how far your procedures are from the text. Your own staff time is the third cost.
What this is not
This is not legal advice. IHS is a consulting firm, not a law firm, and your counsel allocates responsibility between plan, issuer and administrator. It is not a guarantee of compliance. IHS does not post files, build the consumer tool or submit anything to an agency; the plan or its vendor does. Penalties and enforcement are not covered here.
Frequently asked questions
What does Transparency in Coverage require of group health plans and issuers?
It must post price information on a website in machine-readable files (45 CFR 147.212) and give a participant cost-sharing information on request (147.211). Grandfathered plans, account-based plans and short-term limited-duration insurance are outside the sections.
When do the October 2026 changes take effect?
The final rule is effective December 7, 2026, but compliance dates are later. Amended 147.211 applies for plan years beginning on or after January 1, 2027. Amended 147.212 applies beginning March 6, 2027, except the contextual files and website footer link, which apply beginning September 6, 2027.
How often must the machine-readable files be updated?
Monthly under the text in force now, with the update date clearly shown. Under the amended section the in-network rate and out-of-network files are posted quarterly, the prescription drug file monthly, and the taxonomy file quarterly after its September 6, 2027 applicability date. The utilization file is first posted July 1, 2028.
Who is responsible for posting the files when an issuer or administrator prepares them?
For insured coverage under a written agreement, the issuer, but not the plan, violates the requirement if the issuer fails. For other written agreements with a third party, the plan or issuer violates it if the contracted party fails. Your counsel confirms which fits your plan.
What must a plan provide when a participant asks for a cost-sharing estimate?
The 147.211(b)(1) information: an estimate of cost-sharing liability, accumulated amounts, the in-network rate, the out-of-network allowed amount if the request is for an out-of-network provider, notice of any prerequisite, a list of items in a bundled payment arrangement when relevant, and a plain-language notice. It comes through an internet tool or on paper, and under the amended section also by phone.
What is the new phone method?
Amended 147.211(b)(2)(iii) requires the information through the customer-assistance number on the identification card, accurate and provided at the time of the request. The plan may limit providers to no fewer than 20 per day and must tell the caller the limit. It applies for plan years beginning on or after January 1, 2027.
What are the contact text file and the website footer requirement?
The text file is a .txt file in the website root folder with the URL of the page hosting the files, a direct link to them, and a monitored email contact. The footer requirement is a link labeled Price Transparency or Transparency in Coverage. Both apply beginning September 6, 2027.
How should a plan oversee a vendor that produces the files?
Use a written agreement, name an owner, and check the posted files on a calendar. Under amended 147.212(b)(5)(ii) the plan or issuer violates the requirement if the contracted party fails, so oversight stays with the plan.
What does a Transparency in Coverage compliance program cost to build?
The sections state no fee. IHS scopes each engagement after a free introductory call, with no IHS figure on this page. Scope moves with the number of plans, networks and vendors, and the distance from the text.