Making Healthcare Pricing Transparent: Progress, Problems, and the Path Forward

If you're in the healthcare ecosystem of insurance, self-insurance, or benefits consulting, you know how critical healthcare pricing transparency is. Not just for compliance but for helping manage risk and making smarter financial decisions. President Trump's latest executive order, "Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information", released on February 25, 2025, takes important steps in the right direction. But let’s be honest- there's still a long road ahead. Executive orders can set priorities and direct agency action, but they fall short of legislation, lacking the authority to establish enforceable laws or allocate new resources for oversight.

What’s in the Executive Order?

This directive pushes for greater transparency by requiring hospitals and health plans to disclose actual prices for services—not just estimates. Here are a few of the key points:

• Real Prices, Not Estimates: Providers must disclose the actual rates for procedures and services, giving patients and organizations accurate data to work from.
• Stronger Enforcement: The Departments of Treasury, Labor, and HHS have 90 days to update enforcement guidelines to ensure non-compliant organizations face real consequences.
• Building on Existing Rules: The order reinforces earlier requirements, such as publishing machine-readable files (MRFs) with negotiated rates and providing consumer-friendly displays for 300 shoppable services.

While this is encouraging, for those working with price transparency data, the real challenge isn't just accessing information, it's ensuring it's actually published and then making sense of it. If you've ever tried to wrangle MRFs, you know they come with plenty of baggage (e.g., Zombie rates). While the intent is to make negotiated rates more accessible, the reality is far more complicated.

• Inconsistent Formats: Many hospitals still structure their MRFs differently. This makes comparing rates across facilities a nightmare, especially when you're trying to benchmark contracts or optimize reimbursements.
• Questionable Data Quality: Missing or incorrect negotiated rates, inaccurate provider information, and unclear service codes are common problems. While much of the data has improved, there's still a lot of noise. (We spend a lot of time cleansing duplicate or irrelevant rates.)
• Not Built for Real Analysis: MRFs, as the name implies, are designed for machines not people. For analysts and consultants, turning those datasets into actionable insights requires significant data wrangling. (Our product for Price Transparency data aims to solve this.)

The Enforcement Problem

Even though the government is pushing for transparency, enforcement has been weak.

• Low Compliance Rates: A report from Patient Rights Advocate (November 2024) shows that fewer than 25% of hospitals are fully compliant with existing transparency rules.
• Minimal Penalties: While fines exist, many organizations view them as minor inconveniences compared to the effort and cost of compliance.
• Limited Oversight: Enforcement agencies like CMS face resource challenges, making it tough to audit and enforce regulations consistently.

Without strong enforcement, we can't expect hospitals and insurers to be forthcoming with their pricing data. The industry has long been notoriously opaque, with complex contracts, negotiated rates, and billing structures designed to keep true costs hidden. Transparency isn’t in everyone's best interest, especially for organizations that benefit from maintaining information asymmetry. Without meaningful oversight and penalties, there's little incentive for providers to fully comply with price transparency regulations. Many will continue to bury data in inconsistent formats, omit key details, or obscure information to protect margins.

This is why enforcement isn't just a regulatory checkbox; it's essential for creating a level playing field where employers, consultants, and carriers can access the accurate, actionable data they need to drive smarter decisions and reduce costs.

The executive order promises improvements by mandating clearer, more accurate, and actionable healthcare pricing information, but executive orders aren’t legislation. While they can direct agencies like CMS to take action, they don't create new laws or funding mechanisms for enforcement. This means their effectiveness relies heavily on how agencies interpret and implement the directives.

A perfect example of this challenge is the ongoing Rx price transparency loophole, where pharmacy benefit managers (PBMs) have found ways to obscure true rebate amounts despite CMS regulations requiring disclosure. The linked article above in SIIA Self-Insurer (March 2025) highlights how PBMs leverage data aggregation rules to hide rebate details, leaving employers with incomplete or misleading financial data. PBMs often file in the aggregate rather than providing line-item details, making it nearly impossible for plan sponsors to determine their rightful rebate amounts. This loophole remains open largely because enforcement is weak, and CMS regulations don’t fully close the gap.

The healthcare industry has historically been slow to embrace transparency, often citing operational complexities, competitive concerns, or technical limitations. Even with mandates in place, compliance has been inconsistent. Without rigorous enforcement, there is a real risk that many organizations will continue business as usual, providing incomplete or confusing data that is difficult to act upon.

The success of this executive order depends not just on issuing regulations but on holding organizations accountable, enforcing penalties for non-compliance, and ensuring that the published data is truly accessible and meaningful. We’re hopeful that stronger enforcement will push the industry toward true transparency—but history suggests that without legislative action, meaningful change will remain elusive.

The Path Forward

The good news is that momentum for price transparency continues to build. Each new policy, enforcement action, and industry discussion brings greater awareness and pressure for meaningful change. While challenges remain, we're encouraged by the growing demand from employers, consumers, and policymakers for clearer, more accessible pricing data. As agencies refine their approaches and organizations face increasing scrutiny, we’re optimistic that progress will continue. True transparency may not happen overnight, but every step forward strengthens the foundation for a more open, fair, and accountable healthcare system.

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Interested to learn more about how Gigasheet is working to make Price Transparency Data actually transparent? Check out this 90s video 👇