True transparency requires prescription drug rates

Three years ago, Turquoise Health celebrated its own nerdy version of July 4th fireworks with the first posting of Transparency-in-Coverage (TiC) files, which required every payer in the country to post their rates online. We were thrilled, and even had a live tracker to post updates.

However, something was missing: an (at the time) indefinitely delayed third file that would have required payers to post pharmacy rates online. While the TiC files helped lay the foundation for transparent pricing, which included rates from almost every ambulatory surgery center, imaging center, and lab, we couldn’t clearly inform patients of the price of their prescriptions.

Imagine you are in a hospital, being given a painkiller via an IV drip. Chances are, you’ve been involved in an accident or another health crisis. This is not the time to grab your doctor and ask about the price. Ironically, those are the drug rates for which we have pricing information.

But the moment you leave and walk over to your local pharmacy, you enter a pricing black box. While health plans were informed that prescription drug rates would be required, this “third file” was never enforced. Over the last three years, Optum, Avera, and Blue Cross Blue Shield of Texas voluntarily posted their pharmacy rates, showcasing that the burden was not too great to execute this part of TiC.

This is why the Request for Information (RFI) from Internal Revenue Service, Department of the Treasury; Employee Benefits Security Administration, Department of Labor; Centers for Medicare & Medicaid Services, Department of Health and Human Services (referred to as Departments going forward) on Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule is so critical to expanding transparency data into pharmacy rates.

Turquoise Health is in full support of the Departments’ commitment to broadening price transparency requirements to include prescription drugs. Since July 1, 2022, Turquoise Health has mined, enriched, and leveraged the TiC MRFs for contract negotiations between payers/providers and for use by patients in our platform designed to create transaction efficiency.

Our Response's Three Main Themes

Our comments, which you can read in full HERE, have three overall themes:

• Transparency is ultimately about reducing the financial complexity of healthcare and creating a healthcare ecosystem that allows patients to shop for care in advance. Transparent reporting of prescription drug rates is a critical step in building infrastructure that enables patients to receive a comprehensive cost of care before an appointment occurs.
• Turquoise Health supports the Departments creating and sharing a required prescription drug schema on October 1, 2025, and enforcing prescription drug MRFs on February 2, 2026, which aligns with the dates set in the FAQs About Affordable Care Act Implementation Part 70.
• The prescription drug file requirements were originally included in TiC and two additional TiC file requirements have been in effect since July 1, 2022; however, enforcement of the prescription drug file has been indefinitely delayed. Given the Departments’ stated intent to develop technical requirements for the files, we believe the industry will have sufficient time to finalize and post these rates by February 2, 2026. We’ve already seen prescription drug files posted by three payers, which showcase the ability to post these rates with burden commensurate with other stakeholders already posting their rates.

It’s no secret that PBM reform has stalled repeatedly over the last few years. Meaningful reform, regardless of one’s views on how to do it, requires knowing the price of prescription drugs. The enforcement of this third file would be a significant step forward. This is a bipartisan effort, seeing support from both Republicans and Democrats.

Ultimately, transparency creates the social and commercial pressures to make healthcare transactions more patient-centric. When this data becomes public, Turquoise Health will download, standardize, and enrich these files for use by everyone.