Today, the Departments of Labor, Health, and Human Services released several updates in response to the Trump Administration’s Executive Order signed on Feb 25, 2025. Overall, today’s news primarily featured promises of future updates and commitments to additional guidance, additional schema changes, and requests for information. Over the coming weeks, Turquoise will be digging into the specifics and sharing our public comments.

The Departments’ press release focused on a few primary areas:

Hospital Price Transparency

CMS released updated guidance specifically focusing on hospital’s use of encoding 999999999 in the estimated allowed amount (EAA) field within their machine-readable files (MRF). Notably, the use of 999999999 is to be discontinued and the new guidance offers a few different approaches for hospitals to utilize instead:

CMS also issued a Request for Information (RFI) around hospital price transparency, stating

“...to ensure compliance with the transparent reporting of complete, accurate, and meaningful data, CMS seeks public input on whether and how CMS can improve hospital price transparency (HPT) compliance and enforcement processes to ensure that the pricing information in the machine-readable file (MRF) is accurate and complete.”

Payer Price Transparency

CMS released new FAQs addressing the required schemas payers follow when creating MRFs. Within the FAQs, CMS stated that the Departments intend to release a new schema for payers, schema V2.0, which will:

“Implement revised technical requirements for the in-network file and out-of-network allowed amount and billed charges file. In particular, schema version 2.0 will reduce file size by requiring exclusion of duplicative data, reducing unnecessary data fields, and will include updates to better contextualize the data, making it more meaningful to ultimately achieve greater transparency.” (Emphasis added)

The Departments will publish schema version 2.0 on October 1, 2025 and enforcement will begin February 2, 2026.

Prescription Drug Price Transparency

Finally, the Departments jointly issued an RFI seeking “public input on how to improve prescription drug price transparency. The RFI seeks input regarding the prescription drug price disclosure requirements, including information on existing prescription drug file data elements and information on implementation generally, such as the ability of health plans to access necessary data for reporting, as well as state approaches and innovation.”

The RFI is specifically written to address the third MRF originally required by Transparency in Coverage. Requirement of that file remains postponed indefinitely.

Promises of Promises of Guidance Abound

As always, Turquoise is a proponent of clarity, specificity, and quick action around requirements and enforcement dates. Today marks another step towards eliminating the financial complexity of healthcare and getting accurate, timely costs of care in front of patients. However, we are eager for the technical guidance and dates that will hopefully soon follow to ensure measureable, real-world impact of these rules and laws.


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