On October 5, 2026, the Departments of Labor, Health and Human Services and Treasury (Departments) released the Transparency in Coverage (TiC) Final Rule.  The new rule revises final TiC rules previously issued in 2020 and is intended to improve the accessibility, standardization, and reliability of required pricing disclosures.

Most group health plans rely on their insurer or third-party administrator (TPA) to satisfy TiC  obligations. However, plan sponsors should be aware of the new requirements.

Background:​

Group health plans and health insurance issuers are subject to transparency and consumer protection requirements under the 2020 TiC Final Rules and the No Surprises Act.

Under current rules, plans and insurers must disclose detailed in- and out-of-network pricing information and maintain an on-line self-service tool to help plan participants and beneficiaries estimate their cost-sharing liability for covered items and services.

New Final Rule:

The new final rule updates existing data file requirements and introduces new requirements intended to help participants and beneficiaries more easily interpret and use the information.

Improvements to Public Pricing Disclosures

• Changes machine-readable file (MRF) format and data requirements and reduces the required frequency for posting In-Network Rate and Out-of-Network Allowed Amounts MRFs from monthly to quarterly.
• Requires additional contextual files and new hyperlinks on the website home page.
• Requires cost-sharing information from the self-service tool to be made available over the phone (currently required to be online only).   This information must also include new balance billing disclosures.

Attestation Requirement

• A senior official of the plan or insurer must certify that, to the “best of their knowledge and belief,” the information contained in the MRFs is “true, accurate, and complete as of the date in the file”.
• Group health plan sponsors may delegate this responsibility, along with the other TiC  compliance related obligations, to their insurer or third-party administrator (TPA) through a written agreement. 

Key Compliance Deadlines:

• Plan years beginning January 1, 2027 – Changes to the self-service tool and balance billing disclosures
• March 6, 2027– Core MRF changes, attestation requirements, and quarterly reporting cadence
• September 6, 2027 – New contextual files and website hyperlink

Recommended Client Actions:

Insurers and TPAs typically publish MRFs and maintain the cost-sharing tool on their public websites on behalf of group health plans. However, clients should confirm that:

• Written agreements include language delegating compliance-related responsibilities to their insurers or TPAs
• Insurers and TPAs are compliant with existing requirements and are prepared to implement new requirements by the applicable deadlines, including:
  • Update and post MRFs to their public website, along with newly required hyperlinks
  • Create and post newly required contextual files
  • Make cost-sharing information available over the phone and update related notices to include balance billing disclosures
  • A senior official of the carrier or TPA will complete the required attestation on behalf of the group health plan
• Ensure ongoing monitoring of carrier or TPA compliance

Your Piper Jordan account team is available to answer any questions.

Resources:

New 2026 TiC Final Rule, Fact Sheet and FAQs Part 75

2020 TiC Final Rules

Previously Issued FAQ Guidance: Part 53, Part 55, Part 61

Information contained in this email is intended for general information purposes only and should not be considered legal or tax advice or legal or tax opinion on any specific facts or circumstances. Recipients are urged to consult their legal counsel and tax advisor concerning any legal or tax questions that may arise.