In the past, payer contracting had been a “black box” for many medical groups: you knew your own fee schedules and denial pain points, but you rarely knew how your rates compared to other providers in your market, or even whether two similar practices were being paid dramatically differently for the same CPT® code.
The Transparency in Coverage (TiC) rules changed that. By requiring most health plans and issuers to publicly post machine-readable files (MRFs) that include in-network negotiated rates, TiC has made it possible for practices to bring market-rate intelligence into negotiations that used to depend heavily on anecdote, leverage, and persistence.
TiC data can sharpen your negotiating position, but only if you can turn messy public files into usable contracting insights. A Dec. 30, 2025, MGMA Stat poll found that relatively few (18%) medical groups use TiC negotiated-rate data to help in payer contract talks, while most said “no” (46%) or were unsure (36%). The poll had 207 applicable responses.
Among practice leaders where TiC data is used, they primarily use it to set and defend target reimbursement rates during payer negotiations, often leveraging comparisons to competitors to challenge payer assertions. The data is also used for benchmarking — especially at the CPT ® level — to ground contract discussions in market context. While some note limitations due to incomplete payer reporting, most describe using TiC data broadly across rate-setting, benchmarking, and renegotiation efforts once they have it.
In practices not using TiC data, most cite lack of awareness, unclear value, and insufficient tools, time, or skills as the primary barriers to using TiC data. Many also point to structural reasons — such as not contracting with payers, having contracts managed by third parties, or lacking a contracting function altogether — while others note the technical complexity and unusable scale of machine-readable files. Overall for the majority of this week’s respondents, TiC is widely perceived as opaque, resource-intensive, and not yet actionable for their organizations.
Learn more at the 2026 MGMA Financial Conference
During the 2026 MGMA Financial Conference, March 1-3 in Phoenix, Arizona, hear from a trio of experts in “Transparency in Coverage – How to Use Negotiated Rate Data to Negotiate Rates in a Payer Agreement,” a workshop-style session to guide you in building a data-driven business case to use in your next negotiation.
What TiC negotiated-rate data give you
Under the TiC final rule, plans and issuers must publish three MRFs, including an in-network negotiated rate file that lists payer-negotiated amounts with in-network providers for covered items and services (with regular updates). In other words: the “trade secret” part of commercial reimbursement — the contracted rates — has been partially unmasked.
This data is not a turnkey solution, however. It’s more like a massive raw ingredient list. CMS and other federal agencies designed TiC to support consumer price shopping and market competition, but the MRFs were also explicitly made available to other stakeholders (employers, researchers, developers).
Why many practices still aren’t using TiC (yet)
The files are enormous and technically difficult to interpret.
Researchers and analysts describe TiC as massive, complex, and often hard to summarize cleanly — especially across payers — because of how rates are reported, repeated, and structured. Even sophisticated organizations struggle to derive consistent insights without serious data engineering.
“Noise” and oddities can mislead you without cleaning/normalization.
Analyses highlight issues like unlikely rates tied to providers who don’t perform the service, multiple rates for the same provider/service, and reporting structures that change over short periods of time — each of which can skew conclusions if you treat the raw files as gospel.
Data completeness varies by payer and setting.
A December 2025 AJMC analysis of national payers found substantial differences in TiC completeness by payer and service line; notably, physician and outpatient data were generally more usable than inpatient data, but variation remains a real constraint.
Most practices don’t have the internal capacity to “do TiC” alone.
The reality is operational: small to midsize groups rarely have the data staff, time, and tooling to download, map, normalize, and analyze TiC files alongside claims, contract terms, and payer policy changes.
However, the situation is evolving. In December 2025, CMS and the Departments of Labor and Treasury proposed changes intended to reduce file duplication and improve usability (for example, shifting toward network-level reporting and adding more context such as plan/product and enrollment information), signaling that policymakers know the current format is hard to use.
Member benefit spotlight — MGMA Rates
If you want a low-friction entry point into negotiated-rate benchmarking, MGMA Rates, powered by HexIQ, is designed to do exactly that for one of the most important codes in ambulatory care.
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