Almost three years ago, our CEO released our first Price Transparency Impact Report, which stated that this initial phase of price transparency adoption would take five years. The clock started on 1/1/21 and it ends in about six months at the beginning of 2026. The enforcement dates established by today’s updates eerily align with this vision of a second phase of price transparency, one focused on a patient-centric healthcare transaction.

We knew from the beginning that rulemaking was messy, and progress is frequently measured in inches rather than miles. But, three years later, we need more than just progress and will use the new RFIs to continue to voice our recommendations for increased accountability and enforcement of the regulations.

We were initially expecting a late Friday (or even Memorial Day) release of updated guidance from CMS as the 90-day deadline established by the White House’s 2/25/25 Price Transparency Executive order was about to hit on May 26th. Instead, they hit today, and we wrote a quick highlight of those updates here. Today’s updates feel like a long goodbye to that initial phase and the start of something new.

Below is a quick rundown of the good, the bad, and the nuance of simplifying healthcare's financial complexity. It’s easy to legislate around, right?  

The roadmap for 2026 and beyond just started to write itself

The good news: My Memorial Day isn’t going to be totally side-tracked by CMS regulations. We have the beginnings of a roadmap to the future of price transparency in 2026, with enforcement dates, Requests for Information (RFI), and a forthcoming payer MRF schema.

Here’s a quick rundown:

  • The Departments of Labor, Health, and Human Services published two RFIs: (1) Seeking input on whether and how “CMS can improve hospital price transparency (HPT) compliance and enforcement processes”  and (2) public input on “how to improve prescription drug price transparency”
  • The Departments will publish schema version 2.0 on October 1, 2025 and enforcement will begin February 2, 2026

Part D Prescription Drugs & Increased Enforcement All Around

A year and a half ago, I would have laughed if someone had told me that the Part D file in Transparency in Coverage would be making a comeback. It had been indefinitely suspended, and payers were required to post in-network and out-of-network files starting in July 2022. We’re now in a world where CMS isn’t just entertaining a return of the 3rd file of Part D prescription drugs; they are actively seeking guidance in an RFI to implement and enforce the launch of this data.

Payers are about to receive more enforcement and attention. A new schema, Version 2.0, will be released on 10/1/2025, and further enforcement will occur on 2/2/26. This is a significant signal to health plans that there is a future where they will be held just as accountable to requirements as hospitals. While we would have liked to see robust guidance and enforcement happen for both sides simultaneously, we think this new development is the right step toward fair, equitable, and clear enforcement of existing regulations wholesale.

Technically speaking, payer machine-readable files are massive, and the new regulations decrease duplicative data, reduce the total number of files, and include new enhancements like custom place-of-service codes for prices that apply to all locations vs. listing all POS for each negotiated rate.

Like payers, hospitals got updated guidance for posting rates and CMS launched an RFI for feedback on more efficient enforcement.

Congress now has guidance on how the White House views the future of price transparency. A new version of the US Senate bill, PRICE 2.0, is under consideration, and these updated timelines establish clear expectations for that bill. We’ll have more updates on this topic soon.

We’re still measuring progress by inches, not miles

The bad news: I’m going to eat way too many burgers on Memorial Day. There are a lot of future dates, ironic given that I started this blog with our CEO throwing out 1/1/26. Patients are getting impatient as healthcare costs consistently rise. You know it’s bad when we’re celebrating healthcare costs that don't outpace inflation. We recognize why CMS launched two RFIs instead of immediately creating a new enforcement regime—the pressure is on all government organizations. While we wait to see how continued changes will play out, we look forward to contributing our thoughts to build a new healthcare transaction with patients at the center.

The nuanced, uncomfortable truth about healthcare transactions

It’s complicated. In addition to today’s RFIs and enforcement dates, CMS published updated guidance for hospital’s use of encoding the “Nine-9s” in the estimated allowed amount filed within MRFs. The use of 999999999 is going to be discontinued, and new guidance has been posted instead. The intention here is excellent, the execution may need more clarification as hospitals scramble to update MRFs.

Speaking of Nine-9s, there is the question of algorithm use in hospital MRFs. Current regulations are worded in a way that some believe allows almost every rate to be posted as an algorithm, an approach we believe goes against the spirit of the price transparency rules.

We completely agree with the push towards actual prices and will continue to advocate for the burden of bundled, easy-to-shop-for services to be put on payers and hospitals rather than patients.

Phase 1 Price Transparency → Phase 2 Transaction Efficiency

It’s worth taking a step back to where we were in 2020: no MRFs and price transparency remained a buzzword without teeth, stuck in a sea of chargemaster PDFs (remember those?).

In 2025, we have 6,031 hospital MRFs and over 213 payers posting rates. We’ve achieved a singular source of truth for the cost of care in the US. But, the story isn’t over. It took years to organize this data in a way that healthcare insiders could understand it. We haven’t lost sight of who this data is really for: patients.

We cannot wait to share this second phase with you, but I’m happy to give you some hints.