Key Updates in Price Transparency: Transparency in Coverage TiC 2.0
- Jacob Little
- Oct 3
- 3 min read
Updated: Oct 7
TL;DR
CMS released the long-awaited Transparency in Coverage (TiC) 2.0 schema on Oct. 1, 2025. Enforcement begins Feb. 2, 2026.
Major updates: consolidated provider group data, new plan sponsor/issuer fields, and clearer service setting codes.
Improvements reduce file size, improve accuracy, and enable more apples-to-apples comparisons across carriers.
Bottom line: schema 2.0 is a meaningful step forward but leaves a lot of room for stronger improvements.
What to know
Schema 2.0 is the first major update to TiC since September 2023.
The update consolidates provider groups, introduces plan context fields, and improves service setting reporting.
By reducing duplication and adding clarity, data is more consistent, human-readable, and actionable.
However, out-of-network allowed amounts remain hampered by the 20-claim threshold.
Payerset will continue to track CMS updates and provide customers with schema-aligned insights.
Transparency in Coverage 2.0 and why it matters
When CMS announced Schema 2.0, expectations were high. Industry leaders had asked for outlier and carveout details, better out-of-network rules, and overall improved detail to more accurately reflect payer-provider contracts. While not all of these changes were included, this release still represents progress.
At a high level, TiC 2.0 brings higher-quality data, reduced file sizes, and clearer plan-level context. For CFOs and managed care leaders, this means a more reliable foundation for benchmarking rates and comparing contract terms across insurance carriers.
Key schema improvements
Provider Group Data Consolidation
Internal references only: Provider groups must now be defined once and referenced across the file. This should in theory greatly reduce duplication and file size.
Removed separate reference file: All provider group information now lives within the in-network file, preventing dead links and missing provider data.
📊 Impact: Fewer errors from dead links (e.g., Cigna, Geisinger) and easier parsing.
New Plan Identification Fields
Plan sponsor name: Identifies the employer or group sponsoring the plan.
Issuer name: Separates carrier from plan name for clarity (e.g., “Issuer: BCBS Tennessee” vs. “Plan: Premium Plus PPO”).
Clarified plan name field: Now represents only the plan itself.
Product type: Standardized classification (HMO, PPO, EPO, etc.). While this field is not in the schema, it is proposed and documented in the notes. We hope it is included in a fast follow-up update.
📊 Impact: Enables apples-to-apples comparison of plans across carriers. Previously manual workarounds (like Payerset’s own categorizations) can now be automated.
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Service Setting and Place-of-Service Enhancements
"Setting" is a new field that now distinguishes inpatient and outpatient. Previously, inpatient and outpatient information had to be derived from multiple fields.
No empty allowed-amounts lists: Enforces meaningful data if an out-of-network file exists.
📊 Impact: Simplifies alignment between TiC data and claims data (e.g., Type of Bill, POS codes).
DRG Severity (SOI) Attribute
New attribute for Severity of Illness (SOI) within DRGs.
📊 Impact: Allows more precise inpatient benchmarking by distinguishing between base and high-severity DRG payments.
Where schema 2.0 fell short
Out-of-network threshold: The 20-claim minimum rule remains. This means many payers can legally avoid posting OON data. While CMS removed “aggregation to a single provider,” the broader problem may persist.
Missed opportunities: No inclusion of outlier or carveout objects, which would have captured the real nuance of contracts.
📊 Impact: Transparency improves, but contract reality still lags behind.
How to act on this
The good news is that for Payerset customers, no action is required. We will incorporate the new fields and walk you through how to apply them to your analysis. The new data will simply "flow through," and the previous schema will be snapshotted so you can access the historical data and see how these schema updates have materially changed the data and the insights derived from it.
FAQ
When does schema 2.0 enforcement start?
Feb. 2, 2026. Files published after that date must conform to the new schema.
Will schema 2.0 reduce file sizes?
Yes. Provider group references alone dramatically reduce redundancy.
Why is the out-of-network threshold still an issue?
The 20-claim rule often results in payers posting nothing. This reduces transparency rather than protecting privacy.
How does this help CFOs and contracting teams?
With standardized plan identifiers and service settings, comparisons are more reliable. Negotiation leverage improves when contracts are benchmarked accurately and consistently.
What’s next?
CMS has hinted at future schema changes, including drug pricing elements in 2026. From our perspective, this TiC 2.0 update was a half measure, with much left to be desired. We hope this update is not a foreshadowing of what the Drug Price Transparency data will hold.
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