Families USA Submits Comment Letter on Proposed Transparency in Coverage (TiC) Rule
02.26.2026
Families USA, on behalf of the Consumers First steering committee, submitted comments on the Centers for Medicare & Medicaid Services (CMS) proposed Transparency in Coverage (TiC) rule. Consumers First seeks to ensure the nation’s health care system fulfills its obligation to the people it serves by providing affordable, high-quality, cost-effective care to everyone, and transparency in health coverage is foundational to that goal. Consumers First offers these comments to strengthen transparency data to ensure it can be used by policymakers, researchers, and advocates to drive higher value care in the U.S. health care system.
This letter provided several key recommendations:
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Streamline TiC data files by requiring insurers to publish in-network rates by provider network.
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Require insurers to post applicable rates in dollars-and-cents, rather than as a percentage of billed charges.
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Finalize the reporting requirements for additional contextual data files to improve the accessibility and overall utility of TiC data.