Healthcare Pricing Transparency | Position Paper

Commercial health plans pay on average 253% of Medicare rates for the same services, yet machine-readable file (MRF) data meant to enable price transparency contains significant gaps. This position paper identifies five key deficiencies—including missing providers, unexplained rate variations, and misaligned specialty codes—and urges Congress to codify the Transparency in Coverage rule, establish standard file formats, and mandate complete and accurate data. Addressing these barriers could unlock data-driven insights that meaningfully reduce total employer plan costs.