What are machine-readable files and what must employers post?
Last updated October 2, 2026
The Transparency in Coverage rules require health plans to publicly post machine-readable files disclosing in-network negotiated rates and out-of-network allowed amounts, updated monthly. Carriers and TPAs build the files, but employers must ensure a public link exists — commonly on their website.
Machine-readable files (MRFs) are enormous standardized data files exposing what plans actually pay: one file for in-network negotiated rates, another for out-of-network allowed amounts and billed charges. They must be publicly accessible — no login, no fees — and refreshed monthly.
The division of labor:
- Fully-insured plans: the carrier can host and satisfy the requirement by written agreement — get that agreement in writing.
- Self-funded plans: the TPA typically builds and hosts the files, but the compliance obligation stays with the plan; most employers post a public link on their own site pointing to the TPA's files.
The practical checklist: confirm who hosts, post the public link where applicable, verify the link stays live after vendor migrations, and record the arrangement in your vendor documentation.
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