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.

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