Prescription Drugs Rates Get A Mandated Due Date with Dec 2027 Enforcement

The Transparency in Coverage (TiC) prescription drug machine-readable file (MRF) requirement is finally moving from regulatory limbo to an active workstream. The requirement has been on the books since 2020, but unlike the In-Network Rate and Allowed Amount files, which have been enforced since July 2022, the prescription drug file was deferred indefinitely. That changed today when the Department of Health and Human Services (HHS), through the Centers for Medicare & Medicaid Services (CMS), stated for the first time that they "plan to begin working to implement the prescription drug file in short order," and that they are evaluating the June 2025 request for information (RFI) comments to determine how.

We're expecting a May 2027 schema release with a December 2027 enforcement. This announcement is a loud and clear verbal commitment that prescription drug files are finally coming. Here's what that means for drug manufacturers' ability to provide patients a personalized out-of-pocket (OOP) cost for pharmacy benefit drugs.*

*For a detailed breakdown of the technical updates, see "Transparency in Coverage 2026 Technical Updates" at the bottom of this blog.

The new file means an unprecedented view of the prescription drug distribution flow of funds

With the new prescription drug rate MRF, the largest gap in the industry's understanding of the cost of care will suddenly be filled as both pharmacy and medical benefit drug pricing will become available. For drug manufacturers, that doesn't just mean "more data"; it opens a new window into pharmacy benefit reimbursement and their net pricing. Combined with existing medical benefit pricing data, it will enable a more competitive and complete picture when developing market access, pricing, and distribution strategies.

New ways you'll be able to leverage negotiated rates

• Market landscape mapping: analyze how brand and generic products are reimbursed across pharmacy networks.
• Patient affordability and OOP strategy: identify pharmacies offering favorable cost-sharing structures to patients.
• Pharmacy engagement and distribution: assess network pharmacy performance and reimbursement viability to refine distribution model.

New ways you'll be able to leverage historical net prices

• Gross-to-net (GTN) benchmarking: refine forecasting models by evaluating competitor rebate variability and net price trends across pharmacy benefit managers (PBMs).
• Payer contracting: evaluate how historical rebate levels correlate with payer utilization management restrictions.
• Pre-launch planning: use historical net prices of analog therapies to model access expectations for pipeline assets.

And ultimately, the file means an unprecedented ease of delivering out-of-pocket estimates for patients

A monthly pharmacy-level file of negotiated rates and net prices is the missing input for a shoppable experience in the pharmacy environment. Today a patient can see their copay at the counter. But even then, it's very difficult to compare what their plan actually pays across pharmacies unless they choose to pay in cash or with a voucher. That will no longer be a blocker to easily accessible information. Paired with plan design data, the prescription drug file makes personalized out-of-pocket estimates computable before the prescription is even filled. Whereas right now, TiC mandates only the publication of physician-administered drugs, the prescription drug file blows the door wide open for estimating costs where most patients today actually get their drugs: the pharmacy.

It's clear beyond a doubt: the prescription drug file is next on CMS' list

With the final enforcement date confirmed and schema still forthcoming, the directional momentum is clear. The agencies have now said in a final rule that the prescription drug file is next. The necessary scaffolding and government support are in place. All that remains is the required file schema. We will be watching the GitHub repository closely.

The ultimate goal of mandating a prescription drug file is to provide the healthcare industry with the tools to help consumers navigate the confusing ecosystem. For the industry, that means revealing the pricing complexity of the prescription drug distribution chain: how much payers are reimbursing pharmacies for the drug and what concessions payers are receiving from other stakeholders. For consumers, that means using this data to compute personalized OOP costs so that they can truly have a shoppable experience when shopping for the care that they need. It's what consumers increasingly demand, and now it's something you can easily provide.

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Transparency in Coverage 2026 Technical Updates

Back in July 2025, we submitted a detailed RFI response regarding the prescription drug file. It's encouraging to see that input now feeding into implementation across multiple fronts. Our team read through the entire TiC update (we're a riot at parties) and noted all the changes from RFI to final rule as well as the net new inclusions. In short, the new TiC updates will result in significantly simplified and legible payer files, alongside the long-delayed prescription drug file.

What changed from RFI to final rule

Monthly reporting cadence reaffirmed

While some industry commenters advocated for quarterly or annual update cycles, regulators have reaffirmed that a monthly reporting cadence is essential because drug prices fluctuate frequently based on manufacturers' pricing schedules, and a monthly refresh ensures the dataset reflects the latest pricing dynamics.

Executive attestation requirement

These files must now carry an attestation from executive stakeholders that the data published is true, accurate, and complete.

PBM accountability

PBMs can be named by plans as a party they contract with to produce the files, but plans are still liable if the PBM does not deliver the file.

Early voluntary payer file postings

Several major payers and health plans have already begun posting early versions of the prescription drug files on their public websites.

Key ones include:

• Optum
• UHC
• BCBS TX
• Avera
• Baylor Scott & White Health
• Wellmark

Currently these early files primarily populate negotiated rates between payers and the prescription drug dispenser. Fields dedicated to historical net unit price are present but predominantly populated with null values. This reflects the absence of a schema and enforcement date, which is expected to come in the near future.

What has not changed

Key structural requirements outlined by CMS remain consistent since 2020:

• Entity identifiers
• Drug identification: National Drug Code (NDC), including proprietary and nonproprietary names
• Negotiated rates: dollar amounts for each NDC at each in-network pharmacy or dispenser, tied to National Provider Identifier (NPI), Taxpayer Identification Number (TIN), place of service, and contract end date
• Historical net price: dollar amounts per NDC per pharmacy, calculated across a 90-day window starting 180 days prior to publication
• Reporting threshold: a minimum of 20 claims

Also unchanged: none of the schema proposals from the RFI comment period, including Turquoise's recommendations on network references, contract identifiers, and aggregation for low-volume drugs, appear in the regulation. Those will be addressed in the schema itself.