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CMS Transparency in Coverage

Transparency in Coverage

The technical implementation guide for the machine readable files as required by the Transparency in Coverage final rules (85 FR 72158).

Overview

This repository contains a set of schemas describing a data format (example implementations are encoded as JSON and XML) for the Transparency in Coverage final rule. All machine-readable files must conform to a non-proprietary, open standards format that is platform independent and made available to the public without restrictions that would impede the re-use of that information.

Consistent with the Departments’ August 20, 2021 guidance (see below “Guidance” section), the Departments have not promulgated any final guidance with respect to the form and manner for the Prescription Drug File.

Any material currently or previously published on this site with respect to the form and manner of the Prescription Drug File has been superseded and is not guidance of the Departments.

Background

The Departments of the Treasury, Labor, and Health and Human Services (the Departments) have issued the Transparency in Coverage final rules (85 FR 72158) on November 12, 2020. The final rules require non-grandfathered group health plans and health insurance issuers in the individual and group markets (plans and issuers) to disclose certain pricing information. Under the final rules a plan or issuer must disclose in-network negotiated rates, and billed and out-of-network allowed through two machine-readable files posted on an internet website.

Plans and issuers are required to make these files public for plan or policy years beginning on or after July 1, 2022.

Keeping Up To Date

Github allows for people to track and keep up-to-date with any changes for any repository. If you wish to follow and track the changes that happen on this repo, please leverage the "Watch" feature found at the top of the repository and select "All activity". This will email the user that has "watched" the specific repository.

Guidance

Transparency in Coverage rule guidance is released on CMS' website. You can find recently released guidance here:

Developer Documentation

Transport mechanism - HTTPS

All machine-readable files must be made available via HTTPS.

Content type - Non-Proprietary, Open Format

There are plenty of great formats to work with that will meet the needs for Transparency in Coverage:

Examples of proprietary formats that do not meet this definition would be:

Public Discoverability

These machine-readable files must be made available to the public without restrictions that would impede the re-use of that information.

The location of the these URLs must be provided over HTTPS to ensure the integrity of the data.

Robots.txt

To allow for search engine discoverability, neither a robots.txt file nor meta tag on the page where the files are hosted will have rules such that give instructions to web crawlers to not index the page.

This is typically follows the format of <meta name="robots" content="noindex, nofollow"> or for a robots.txt file using the Disallow directive.

Special Data Types

Dates should be strings in ISO 8601 format (i.e. YYYY-MM-DD).

Different Machine-Readable Files

There are two required machine-readable files associated with Transparency in Coverage:

  • In-Network Negotiated Rates
  • Out-Of-Network Allowed Amounts

In-Network Negotiated Rates File Under the finalized rules, a plan or issuer must disclose in-network provider negotiated rates for all items and services through a machine-readable file.

Out-Of-Network Allowed Amounts File Under the finalized rules, a plan or issuer must disclose certain data elements to the public, including the billed and allowed amounts for out-of-network providers, through a machine-readable file.

The associated names for those files are:

  • in-network-rates
  • allowed-amounts

Timing Updates For Machine-Readable Files

According to the TiC Final Rules and the schema requirements, plans and issuers are required to update the machine-readable files monthly and populate the attribute last_updated_on. The Departments consider “monthly” to refer to reasonably consistent periods of approximately 30 days, but are not specifying a particular day of the month.

File Naming Convention

There are scenarios where multiple plans have exactly the same negotiated rates with the same group of providers for the same items and services. This would lead to a large duplication of reporting. Also, there are plans that will be unique in their negotiated rates that would require a separate file.

The producers of the files have the option to group multiple plans together with the same negotiated data (or allowed amounts). If plans are to be grouped together, a table-of-contents file will be required to capture all the different plan data along with a URL location on where to download the appropriate files.

Payer/Issuers are still allowed to build both in-network and allowed-amount files for a single plan. The naming conventions will be different for each.

For payer or issuer's names that have spaces, those spaces would be replaced with dashes -

Only alphanumeric characters are allowed in the file name. No special characters such as ' are allowed. Special characters are either to be removed completely or replaced with -.

Single Plan Files

The following is the required naming standard for each file: <YYYY-MM-DD>_<payer or issuer name>_<plan name>_<file type name>.<file extension>

For example, the following would be the required naming for CMS building a JSON file:

  • 2020-01-05_cms_medicare_in-network-rates.json
  • 2020-01-05_cms_medicare_allowed-amounts.json

An example of a plan named healthcare 100 with an issuer's name issuer abc producing a JSON file, the following would be the naming output:

  • 2020-01-05_issuer-abc_healthcare-100_in-network-rates.json
  • 2020-01-05_issuer-abc_healthcare-100_allowed-amounts.json

Multiple Plans Per File

If multiple plans are to be included in a single file, a table-of-contents file will be required. The naming standard will be applied to the table-of-contents file and both the in-network and allowed-amounts files will not have any naming standards.

The following is the required naming standard for the table-of-contents file: <YYYY-MM-DD>_<payer or issuer name>_index.<file extension>

For example, the following would be the required naming for CMS building a JSON file that includes Medicare and Medicaid plans:

  • 2020-01-05_cms_index.json

Schemas

Examples

Getting Involved

The healthcare ecosystem is complex with what seems like an infinite amount of plan and issuer implementations. There are no doubt going to be questions for these various situations and the requirements found in the Transparency in Coverage rule. Currently, there are two ways in which the community can get involved:

  • Github Issues - Where people discuss issues related to the project.
  • Github Discussions - Use these channels for conversational topics (for example, "How do I…" or "What do you think about…" instead of bug reports or feature requests).

Before posting a comment, issue, or question, please search through existing discussions and issues. There is a good chance that the topic in questions is already being discussed.

Versioning

With any type software development, progression happens through bug fixes, new content, or changing requirements. The technical development of this schema is no different. CMS will be following the standard versioning found in many software development projects with including a major, minor, and patch number to represent the current version of the schema. The following is the guiding principles for version updates:

MAJOR version when incompatible changes are introduced, MINOR version when attributes/values are introduced or removed in a backwards compatible manner, and PATCH version when backwards compatible bug fixes are introduced.

The major version will be finalized to 1.0.0 for the schema to adhere to the July 2022 implementation date. Versioning of the schema can be tracked in the VERSION.md file.

Schema Validator Tool

CMS developed a downloadable schema validator tool that plans and developers can use to assess whether their machine readable files are compliant with the Transparency in Coverage JSON schema. The validator tool and instructions can be accessed here. The tool can be used to validate in-network and allowed amount files, as well as provider references and table of contents files. Note that the tool tests for attributes required under version 1.0 of the JSON schema and for syntax errors, but does not test the accuracy of the data in the schema. It is designed to run on local computers and can be used to validate files of any size (there is no file size limit). At this point in time, the validator tool can only be used to validate JSON files.

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The technical implementation guide for the tri-departmental price transparency rule.

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