CMS Needs to Make MRF Compliance Simpler

UPDATE: CMS made the change HealthSparq recommended to the plan ID. The MRF schema has been updated to have the plan ID as an array within the file instead of one file per plan ID. This will be a great improvement to reduce the risk of having many massive files.

In October 2020, CMS issued the Transparency in Coverage final rule mandating that health plans publish machine-readable files (MRFs) on their negotiated rates, out of network allowed amounts, and prescription (Rx) coverage rates and allowed amounts. The Rx file was recently deferred indefinitely, but public access for the other two still stand. Despite the new enforcement date of July 1, 2022, there are still compliance challenges for plans and groups. One area of particular concern is the data schema. The MRF schema creates major problems—for both the MRF creators and the public consumers of the files.

Major issues with MRF data schema include: 

• Data redundancy. The proposed MRF schema has significant data redundancies that result in a massive amount of data duplication, aspects of which many health plans are likely struggling to manage.  
• Massive files. The data schema results in many massive files that are unconsumable for the public via the download mechanism that CMS requires. The files may be in the terabyte size range. 
• Non-downloadable, costly data. Files can’t be downloaded via https and are costly for health plans to host online. 

Our team already provided comments to CMS on changes around plan identifiers, place of service codes, and provider identifiers. We anticipate these changes could significantly reduce file size. CMS has already published changes around place of service codes and this week our team met with CMS to discuss the other data elements: 

• Plan identification: Each file is organized by plan ID. It is common for many plans to leverage the same underlying contract rates which results in a massive duplication of data when there are potentially thousands to hundreds of thousands of plans using the same rates. Our recommended approach is to shift from one file per plan ID to instead list the plan IDs as an array within a file for all plans on the same contract.
• Provider identifiers: This requires plans to duplicate the provider list over and over. This is redundant and makes the files unwieldy. The recommendation here is to list the NPI and TIN as an object under the negotiated rate.

We know others in the industry have expressed concerns about the schema, as well as the data being shared in these files. Based on our interactions with CMS, we expect an additional review process with impacted plans and anticipate updates to the schema to address the issues we noted with plan and provider identifiers. 

HealthSparq’s product and regulatory experts are monitoring for additional updates on price transparency mandates and the MRF data schema. We’ll be updating our clients on relevant changes as soon as we learn of them in order to support their compliance efforts.