Transparency in Coverage: Moves that bend cost
Learn how Transparency in Coverage data can help employers assess negotiated health care prices and inform cost management strategies.
For employers, understanding what drives health care costs can be challenging. Premiums, claims reports and network discounts provide important information, but they may not show how negotiated prices vary among providers, facilities and health plans. Transparency in Coverage (TiC) data adds another layer of insight.
Under federal TiC requirements, most non-grandfathered group health plans and health insurance issuers must publicly disclose certain pricing information in machine-readable files, including network rates for covered services and resources.1
For employers and their advisors, that information can provide a closer look at the prices negotiated within a network. The opportunity is not simply having access to more data but rather using that information alongside other plan data to better understand potential cost drivers.
What can employers learn from TiC data?
TiC data can allow employers and their advisors to compare negotiated rates by provider, service and network. That is different from claims data, which shows the services plan members actually used, reflecting adjudicated costs. TiC files do not provide a complete picture of utilization or quality and may not reflect every contractual factor that affects a final claim amount.2
Used together, however, these sources can help answer more specific questions about health care spending. For example, claims data may show significant spending on imaging. TiC data may help assess how negotiated rates for those services differ across providers or sites of care. Quality and utilization data can then provide additional context for evaluating potential opportunities.
Why a bigger network discount may not mean a lower price
A network discount percentage does not necessarily tell an employer which provider or network has the lower negotiated price.
Consider a provider that bills $20,000 for a service and has a negotiated rate of $10,000. That represents a 50% discount. A second provider might bill $12,000 and have a negotiated rate of $9,000. Its discount is smaller at 25%, but its negotiated price is lower.
TiC data can give employers another way to evaluate network costs by focusing on negotiated rates for specific providers and services.
Recent research using TiC data illustrates how widely those rates can vary. A 2025 analysis of commercial negotiated rates found substantial price differences for the same procedures across facilities and health plans.3 For employers, the goal is not simply to identify the lowest negotiated rate. It is to understand how price, provider quality, access, utilization and member needs work together across a network to reduce cost of care. Evaluating carriers based on their ability to influence overall cost of care can deliver value that extends beyond a network discount. For example, UnitedHealthcare was found to deliver a more than 11% lower total cost of care compared to national benchmarks by a third-party actuarial firm.4
5 questions TiC data can help employers answer
1. Where is there significant provider price variation?
Negotiated rates for the same service can vary across providers, facilities and health plans.3 Identifying those differences may help employers determine where additional analysis is warranted. A higher or lower price alone does not determine value, but significant variation can provide a starting point for asking why those differences exist.
2. Where are there site of care opportunities?
The setting where care is delivered can affect cost. A 2025 Health Care Cost Institute analysis examined 57 services that may be delivered in either hospital outpatient departments or physician offices. For every service studied, prices were higher in the hospital outpatient setting. In 2022, the difference ranged from 1.27 to 13.5 times the physician-office price.5
TiC data can help identify similar price differences within a network, while claims data can help employers understand where plan members are receiving those services and how to better educate them on appropriate site of care usage.
Beyond education, it's worth considering whether a carrier's navigation tools and cost-and-quality indicators within the provider search experience make those differences visible to members at the point of decision — helping them directly select lower-cost, quality providers and facilities rather than relying on education alone.
3. Are network prices competitive?
Network breadth is one consideration when evaluating a health plan, but TiC data may help employers and their advisors compare negotiated rates at providers and facilities that are particularly relevant to their workforce. This can provide additional context alongside traditional measures of network performance and value, such as access, provider quality and discounts.
4. Which services are contributing most to cost variation?
Not every price difference has the same impact on overall spending. A large price difference for a rarely used service may have less financial impact than a smaller difference for a frequently used service. Combining TiC data with claims and utilization information can help employers focus on areas where both price variation and utilization are meaningful.
5. How can transparency insights inform renewal discussions?
TiC data can help employers and their brokers or consultants ask more targeted questions during renewal. For example: How do negotiated rates compare for frequently used services? Are there meaningful differences among key facilities? Could certain services be delivered in other settings?
Those questions may help inform broader discussions about network strategy, site of care programs and other cost management approaches.
Price is only one part of measuring value
TiC data can provide greater visibility into price, but price alone does not measure health care value. Quality, outcomes, access and utilization also matter. A provider with a lower negotiated rate is not necessarily the better option if other factors affect the quality or total cost of care.
There are also practical limitations to TiC data. Researchers and federal regulators have identified challenges related to the size, complexity and usability of the machine-readable files.2 For most employers, translating the raw data into useful insights may require analytics capabilities and additional claims, utilization and quality information.