Turquoise Health public comment on CMS-9882-P

On the heels of December's Transparency in Coverage proposed rule, which seeks to evolve the data included in payer machine-readable files (MRF). Turquoise has submitted a public comment focused on a number of different areas. Summarily, we:

• Support clearer standards and definitions, particularly around provider networks, and stronger structural guidance to improve rate uniformity
• Request clarity to create a more structured file ecosystem, including a robust table of contents (TOC) that clearly links plans, networks, and related files
• Point to alignment with hospital price transparency efforts so MRF standards converge
• Align with the Departments’ changes that improve data completeness and usability, including enhanced out-of-network allowed amount reporting and additional files providing contextual data
• Affirm the Departments’ prioritization of accessibility and automation, backing standardized file discovery, removal of technical access barriers, and a single open format (JSON)
• Recommend practical, proportionate implementation timelines

You can download and read our entire comment here.