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David Muhlestein, PhD, JD

Improving Transparency in Coverage Data: Reducing Ghost Rates, Adding Utilization, and Standardizing File Structure

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

David Muhlestein, PhD, JD

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