Price transparency regulation has two separate tracks — one for hospitals, one for health plans — and both moved in 2026, but at very different speeds. The hospital side saw a real, enforceable update take effect this year. The payer side is still sitting in proposed-rule limbo. If you work across both hospital and payer-facing revenue cycle functions, it’s worth being precise about which rule applies to which side of a claim, because “price transparency” in 2026 means genuinely different things depending on which party you’re talking about.
Hospital price transparency: a real update, already in force
CMS’s hospital price transparency rule requires hospitals to publish standard charges — including payer-specific negotiated rates — in a machine-readable file (MRF), along with a consumer-friendly shoppable services display. For calendar year 2026, CMS finalized a meaningful methodology change to how hospitals must report negotiated rate data:
- The “estimated allowed amount” reporting method is being replaced with more granular, verifiable figures: the median allowed amount, the 10th and 90th percentile allowed amounts, and the count of allowed amounts underlying those figures. Hospitals must derive these numbers from actual payment data — specifically EDI 835 electronic remittance advice transactions or an equivalent data source — using a 12-to-15-month lookback period, rather than the more loosely defined estimation methods some hospitals had been using.
- A CEO or senior official attestation must now be embedded directly in the machine-readable file, affirming that the standard charge information is true, accurate, and complete.
- Type 2 (organizational) NPIs and corresponding taxonomy codes must be encoded in the files, improving the ability of downstream users (researchers, payers, price-comparison tools) to match hospital pricing data to the correct facility.
These changes were effective January 1, 2026 for most requirements, with a compliance and enforcement deadline of April 1, 2026 specifically for the median/percentile amounts, the attestation requirement, and the NPI/taxonomy encoding. CMS enforcement of these specific updated requirements began on that date, meaning by now hospitals should have fully transitioned MRFs in place — if your organization hasn’t verified its current files meet the new methodology, that’s an overdue task, not a future one.
CMS also adjusted its civil monetary penalty (CMP) process: hospitals that receive a penalty notice can now get a 35 percent reduction in the penalty amount if they waive their right to an Administrative Law Judge hearing within 30 calendar days of the notice — though this reduced-penalty pathway is not available to hospitals that failed to post machine-readable files at all, which CMS continues to treat as the most serious category of noncompliance.
Payer price transparency: still a proposed rule
On the health plan side, the Transparency in Coverage (TiC) rule requires payers to publish in-network negotiated rate files and out-of-network allowed amount files. In December 2025, CMS issued a substantial proposed rule (CMS-9882-P) aimed at addressing longstanding complaints that TiC files are too large, poorly organized, and hard to reconcile with hospital-side pricing data. Key proposed changes include:
- Reorganizing in-network rate files by provider network rather than by individual health plan, which would reduce substantial file duplication.
- Adding product type and network name identifiers, current enrollment counts, and excluding provider-service combinations that are clinically implausible (for example, a specialty-service pairing that would never realistically occur).
- New contextual files — a change-log file, a utilization file, and a taxonomy file — to help users interpret and update against the core rate files.
- Shifting in-network rate file updates from monthly to quarterly.
- For out-of-network allowed amount files: reporting at the health insurance market level instead of the individual plan level, lowering the minimum claims threshold from 20 to 11 claims per service, expanding the reporting period from 90 days to 6 months, and extending the lookback period from 180 days to 9 months.
- Requiring a discoverability text file listing URLs and contact information for all of a payer’s machine-readable files, plus a footer link on the payer’s website pointing to where those files live.
As of this writing, this remains a proposed rule — the public comment period, after an extension, closed in late February 2026, and CMS has not yet issued a final rule. Practices and billing companies should not treat any of these proposed changes as currently enforceable; the existing TiC file requirements from the original 2020 rule remain in effect until (and unless) this proposal is finalized.
Why this matters for RCM teams, not just compliance staff
Billing and revenue cycle teams increasingly use both hospital MRFs and payer TiC files as a reference point when evaluating whether a contracted rate or an out-of-network payment looks correct — the hospital-side update in particular makes that comparison meaningfully more reliable, since median/percentile figures anchored to actual remittance data are a much better benchmark than the old estimated-allowed-amount approach. Teams that had built internal rate-benchmarking tools off the old hospital MRF format should confirm those tools have been updated to parse the new percentile-based fields correctly, since the file structure itself changed, not just the underlying numbers.
What to actually do
- Verify your hospital’s (or your hospital clients’) MRFs were updated to the new median/percentile methodology by the April 1, 2026 deadline, if you haven’t already confirmed this.
- Update any internal rate-benchmarking tools or spreadsheets that were built to parse the old “estimated allowed amount” field, since the new file structure uses different fields entirely.
- Do not build payer-side workflows around the proposed TiC changes yet — track CMS-9882-P’s status, but treat the current (2020-rule) TiC file requirements as what’s actually in effect until a final rule is published.
- Flag both rules for your compliance calendar separately, since they’re on entirely different tracks — hospital-side enforcement is live now, payer-side reform is still pending.
Takeaway
Hospital price transparency got real teeth in 2026, with new median/percentile reporting enforced since April 1 and a stricter attestation requirement. Payer-side Transparency in Coverage reform is still just a proposed rule as of this writing — track it, but don’t build workflows around it until CMS actually finalizes it.
For the patient-facing side of this — the tools and estimates individual patients actually see before a service — see our guide to patient cost estimators, including how the Good Faith Estimate and its dispute process actually work today.