February 2nd, 2026 marked the first enforcement deadline for Transparency in Coverage Schema 2.0, a significant change to how payer data is published and accessed. We've been parsing the latest MRFs and wanted to share what we're seeing on the ground. We plan to update this post each quarter as payers continue adapting to the new requirements Schema 2.0 is the first step. We recently did a deep dive in to proposed rules for 2027 and beyond. Refresher: What's New in Schema 2.0

TL;DR CMS is proposing some of the most significant updates to TiC requirements since its inception. Plans would consolidate rate files by provider network instead of by individual plan , dramatically increasing usability. Annual Utilization File would show which providers actually received reimbursement for a given service In-network and out-of-network files move from monthly to quarterly updates Enhanced out-of-network data : Claims threshold drops from 20 to 11, reporting