Publications, press releases, and news from the Simple Healthcare team — peer-reviewed research, white papers, and policy analysis on healthcare price transparency.
In this 2026 article published in BenefitsPRO, David Muhlestein and Elvira Makk Frid how price transparency data and negotiated rates can help employers, especially during the renewal cycle. The article explains how pricing data, when combined with claims, can better inform decisions about network selection and healthcare spending.
This National Academy of Medicine discussion paper examines how payment incentives, fragmented care, and complex policies affect health outcomes. Co-authored by David Muhlestein, it outlines 12 potential reforms and their trade-offs
Slides from Simple Healthcare’s April 28, 2026 presentation to Senate Finance Committee Office Hours on using healthcare price transparency data to identify opportunities to reduce commercial healthcare spending.
These state profiles compare published healthcare prices across insurers and providers. They explain what local price differences mean for employer purchasing decisions and identify limitations in the underlying transparency data.
Maryland was excluded from the analysis due to a lack of data.
This work is funded by the Peterson Center on Healthcare (PCH). We are thankful for their support.
Click on each state to review the PDF.
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In a new article published in the American Journal of Managed Care: Population Health, Equity & Outcomes, we examine the significant variation in healthcare prices across providers and payers—and what it means for lowering costs in the U.S. healthcare system.
Using examples from knee replacement surgery in New York City, the article highlights how prices for the same procedure can vary dramatically depending on the hospital and insurer. These disparities illustrate both the scale of inefficiency in current pricing structures and the opportunity to reduce costs through better use of price transparency data.
While transparency has improved access to pricing information, the article emphasizes that information alone is not enough. The central challenge is making this data actionable—ensuring it reaches the right stakeholders in a usable form at the right time to inform real-world decisions.
In this article, published in The American Journal of Managed Care, David Muhlestein explores how healthcare price transparency is only the first step toward reducing costs—and why simply making data available is not enough. It highlights how employers, payers, and innovators are increasingly leveraging detailed pricing data to drive actionable strategies, such as steering patients to high-value providers, improving contracting decisions, and redesigning benefits. While transparency can enable more informed decision-making and foster competition, its real impact depends on how effectively stakeholders translate data into behavior change and system-level interventions that lower spending and improve value.
In February 2026, Simple Healthcare submitted a comment letter on the proposed updates to the Transparency in Coverage (TiC) rule. Based on our extensive experience analyzing TiC data, we strongly support efforts to improve data quality and usability, while highlighting key structural issues such as “ghost rates,” incomplete reporting, inconsistent network definitions, and file formats that limit real-world use.
We recommend adding provider-group level procedure volume, combining claims-based utilization with specialty taxonomy to reduce ghost rates, improving bundled payment disclosure, standardizing network identifiers, reporting average paid amounts, and requiring relational (rectangular) file formats instead of nested JSON. These changes would make TiC data more accurate, accessible, and actionable for employers, researchers, and policymakers.
Simple Healthcare’s white paper provides technical recommendations to help strengthen the proposed Transparency in Coverage rule from the Centers for Medicare & Medicaid Services by improving how price transparency data is structured, reported, and filtered. Drawing on empirical analysis of current TiC data, the paper outlines 17 practical, implementation-ready recommendations across ghost rate filtering, utilization reporting, bundled payment disclosure, and machine-readable file architecture. The goal is to help ensure transparency data is accurate, interpretable, and usable for real-world decision-making by employers, researchers, and policymakers, while remaining feasible for payer implementation using data already maintained within existing systems. The analysis was developed by Simple Healthcare to support more effective use of transparency data in purchasing, policy analysis, and market oversight
Simple Healthcare has released a press release announcing its latest white paper focused on improving the usability and real-world impact of Transparency in Coverage data. The release highlights how specific technical implementation decisions within the proposed rule from the Centers for Medicare & Medicaid Services could determine whether price transparency data can be effectively used by employers, researchers, and policymakers. The press release summarizes the paper’s core findings and outlines 17 practical, implementation-ready recommendations across ghost rate filtering, utilization reporting, bundled payment reporting, and machine-readable data architecture.
The press release also reinforces Simple Healthcare’s focus on advancing practical, evidence-based solutions that help transparency policy achieve its intended goals. By translating complex technical recommendations into clear, actionable policy direction, the white paper and accompanying press release are intended to support policymakers, industry stakeholders, and market participants working to make healthcare pricing data more accurate, interpretable, and decision-ready.
Simple Healthcare has released a new white paper, History of Price Transparency in U.S. Healthcare: How Healthcare Became a Market Without Visible Prices, that chronicles how the U.S. healthcare system evolved into one of the few major markets where prices have historically been opaque. The paper traces the shift from direct payment to complex financing, managed care, and negotiated contracts that separated care delivery from clear prices, leaving patients, employers, and purchasers without meaningful price information. While recent federal mandates like the Hospital Price Transparency and Transparency in Coverage rules have made millions of negotiated rates publicly available, the paper emphasizes that disclosure alone isn’t enough — inconsistent formats, data quality problems, and complexity hinder usability. The next phase of transparency must focus on transforming raw data into clean, validated, decision-ready intelligence to support better choices, stronger purchasing power, improved negotiations, and more effective oversight across the healthcare market.
For decades, U.S. healthcare has operated as a market without visible prices — an anomaly unlike almost any other sector of the economy. How Healthcare Became a Market Without Visible Prices explores how this system evolved, tracing the shift from direct-pay medicine to a complex web of insurance, contracts, and payment models that embedded prices deep within private negotiations. The paper explains why transparency efforts historically fell short, and how well-intentioned reforms often increased complexity without improving real-world decision-making.
Today, healthcare has crossed a one-way threshold. Federal transparency rules have made negotiated prices technically public, but disclosure alone has not created accountability, competition, or better purchasing decisions. This paper argues that the next phase of price transparency will be defined by whether the industry can convert fragmented disclosures into trusted, decision-ready intelligence. Doing so is critical to improving negotiations, enabling smarter purchasing, informing policy, and ultimately restoring price as a meaningful economic signal in healthcare.
McKnight’s Senior Living highlighted a recent Simple Healthcare analysis that evaluates how well the three largest health insurers comply with federal Transparency in Coverage (TiC) requirements by reporting complete negotiated price data. The piece notes that Simple Healthcare’s research found significant gaps in insurer-reported data, meaning employers and other purchasers may struggle to compare costs and make informed decisions because key negotiated rates are missing or incomplete in publicly accessible TiC files.
The coverage emphasizes the broader implications of these data gaps for employer healthcare affordability efforts, underscoring how incomplete TiC disclosures can undermine transparency policy goals and limit stakeholders’ ability to leverage price information for benefit design and cost negotiation.
Axios featured a recent paper by Simple Healthcare analyzing how completely major insurers disclose negotiated prices under federal transparency rules. The report found that UnitedHealthcare, Aetna, and Cigna all left gaps in their data, with Aetna disclosing only about half of common hospital outpatient rates and UnitedHealthcare reporting just 8% of hospital inpatient pricing — despite high completeness in other service categories.
The article also includes comments from payers disputing the study’s conclusions — Cigna called any suggestion of noncompliance “false,” and UnitedHealthcare said it aims to provide “clear, complete and actionable data.”Axios noted that the Centers for Medicare & Medicaid Services (CMS)has not taken public enforcement action, even as regulators reaffirm commitments to transparency oversight.
Becker’s Payer Issues reported on Simple Healthcare’s evaluation of 2025 Transparency in Coverage (TiC) files, showing that major insurers are not fully meeting federal disclosure expectations. The article detailed the study’s methodology — comparing published provider counts and negotiated rates across specialties and settings — and found particular weaknesses in hospital inpatient and outpatient data.
Becker’s also highlighted that no insurers have been publicly fined by CMS for noncompliance, even as hospitals face penalties for their own transparency violations. The report included insurer responses disputing the findings and noted broader regulatory context, including a 2025 executive order and updated federal guidance to improve TiC data quality
TechTarget covered Simple Healthcare’s study assessing compliance with the Transparency in Coverage rule, which requires insurers to publish machine-readable negotiated rates. The report found major gaps in the completeness of pricing data across the three largest U.S. payers, with Aetna reporting roughly half of hospital outpatient codes, Cigna showing very limited outpatient disclosures, and UnitedHealthcare reporting strong physician specialty data but minimal inpatient pricing.
The piece also quoted research stakeholders — including Simple Healthcare’s principal author — highlighting that incomplete data makes it harder for employers and individuals to use transparency tools for cost comparison. TechTarget pointed to upcoming federal guidance and updated data schemas that may help improve compliance and usability.
In this paper, the authors analyzed 2025 publicly available Transparency in Coverage (TIC) machine-readable files from three major national insurers — Aetna, Cigna, and UnitedHealthcare — to assess how complete the data are for physician, hospital outpatient, and hospital inpatient service lines. The analysis revealed wide variation by insurer and service type: Aetna and Cigna generally listed as many—or more—physicians and hospitals as their marketing materials did, whereas UnitedHealthcare listed fewer.
Physician specialties and outpatient hospital services were much more thoroughly documented; however, inpatient hospital data were often sparse or incomplete. The authors conclude that while TIC data today can support analyses of prices for physician and outpatient hospital services, they are inadequate for reliable inpatient benchmarking— and recommend that the Centers for Medicare & Medicaid Services (CMS) audit insurers’ TIC data and enforce compliance to improve data quality.
Research by Simple Healthcare CEO highlights major data quality challenge in Transparency in Coverage files. A new study published in Health Affairs Scholar finds that “ghost rates”, or negotiated prices listed for services that providers almost certainly never perform, are highly prevalent in insurer Transparency in Coverage (TiC) files, raising concerns about the usability of federal price transparency data.
New platform puts nationwide negotiated rates at users’ fingertips, empowering healthcare industry leaders with actionable insights at no cost. Designed for investors, life science teams, and physician groups, this tool is a one-of-a-kind resource that allows users to compare prices by payer, billing code, and region completely free of charge—turning complex Transparency in Coverage (TiC) data into clear, actionable insights.
David Muhlestein assessed ghost rates in Transparency in Coverage files from 61 insurers using utilization and provider specialty information. The study found widespread implausible provider-service combinations and recommends reporting procedure volumes.
Simple Healthcare’s latest publication emphasizes how negotiated rate data can guide smarter investment decisions across the healthcare sector. The new white paper, new white paper, From Data to Deal: Price Transparency Data for Private Equity Investors, examining how the availability of hospital and insurer Price Transparency data is reshaping healthcare investment strategies.
In this white paper, Elvira Makk Frid Frid examines how publicly disclosed negotiated rates can inform healthcare investment analysis. Without information on negotiated rates, the true picture of healthcare prices has remained blurry. The recent Price Transparency rules promise to bring some much-needed clarity.
As the healthcare landscape continues to evolve, price transparency has the potential to shift how investors evaluate opportunities and risks, providing a clearer foundation for strategy and decision-making.
A new report from the Commonwealth Foundation discusses how physician payments are set in Medicare under the Resource-Based Relative Value System (RBRVS), and how this process has historically led to primary care being undervalued.
A recent analysis in Health Affairs Forefront calls for CMS to reform physician payment to reflect the value of cognitive effort in primary care. The article, published in Health Affairs Forefront, proposes four key policy recommendations for CMS, and calls for a re-evaluation of how the relative value units (RVUs) work components are calculated for primary care.
In this article, David Muhlestein argues that payer-driven healthcare price transparency holds promise for enhancing competition and facilitating informed decision-making across the healthcare system. However, multiple barriers—including inconsistent data formats, incomplete coverage of services (particularly drugs and volumes), and a lack of clarity regarding data sources—are limiting its usability. In response, this article outlines five key recommendations to improve the practical utility of transparency data in real-world settings:
Deliver data in a relational structure to enable easier sorting, querying, and integration with other datasets.
Report data provenance and structure (i.e., data location and source context) to enhance interpretability and trust.
Include drug price data within transparency disclosures, recognizing pharmaceuticals as a critical component of total healthcare costs.
Incorporate volume data, which provides context for price variations and helps assess whether rates reflect typical or outlier use.
Report negotiated rates, not just list prices, so that transparency reflects the actual costs paid by payers and consumers.
These recommendations, born out of practical experience, aim to unlock the full potential of price transparency by making data more accessible, actionable, and meaningful for policymakers, researchers, providers, employers, and patients alike."
A new report urges reforms to improve healthcare price transparency, making data more accessible and usable for patients, employers, and policymakers. The report, featured in Health Affairs Forefront, underscores the need for regulatory improvements to make hospital and insurer price transparency data more accessible and useful for patients, employers, and policymakers.
Yuvraj Pathak and David Muhlestein analyzed more than 1.3 million negotiated rates across 1,784 hospitals. Their cross-sectional study found an association between greater hospital system market share and higher commercial inpatient prices.
A national survey found limited awareness and use of hospital price information, alongside strong support for enforcement. Yuvraj Pathak and David Muhlestein examine the implications for public education and transparency policy.
The Hospital Price Transparency Rule, effective January 2021, mandates that U.S. hospitals publicly post prices for 200 shoppable services in a machine-readable format, with penalties for noncompliance. Yet, compliance has been uneven: only 57% are fully compliant, while 31% report partial compliance; some studies show compliance as low as 36%.
Noncompliance stems from several factors:
Hospitals needing more time or resources to compile accurate data;
The high cost of compliance itself;
Concerns that disclosing negotiated rates might weaken their competitive bargaining position—although Transparency in Coverage rules now require payers to report those rates independently, reducing this concern.
To address these challenges, the article proposes several policy interventions:
Substantially raise enforcement penalties: CMS has already increased fines up to $2,007,500 annually for large hospitals—aligning the cost of noncompliance with, or exceeding, the cost of compliance.
Capitalize on payer-based transparency initiatives: As insurers are required to disclose negotiated rates under new Transparency in Coverage policies, hospitals' compliance—or lack thereof—has less competitive risk.
Launch public awareness campaigns: Informing consumers about price transparency and its benefits could drive demand for the data, increase usage, and incentivize hospitals to comply.
Overall, achieving the goals of transparency—empowering consumers and encouraging healthcare competition—requires both stronger enforcement and enhanced public engagement.
David Muhlestein compared four national insurer networks using third-quarter 2022 Transparency in Coverage files. The analysis examines negotiated prices, provider overlap, reporting differences, and ghost codes that complicate interpretation.