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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
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