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More health plan transparency means the future is now: What you need to know

March 2026 employment law letter
Authors: 

Brandon Long, McAfee & Taft

Using a multipronged approach, the federal government is aggressively promoting greater transparency and understanding of costs and pricing in the healthcare and health insurance market. Indeed, last month, the U.S. Departments of Labor (DOL), Health and Human Services, and Treasury issued new proposed regulations that expand the requirements under existing transparency regulations relating to machine-readable files. The new proposed regulations, the existing transparency regulations, the hospital price transparency initiative, and the No Surprises Act collectively represent a push and movement by the federal government to empower patients with meaningful price information.

Now, states are also taking action.

State financial officers ask companies to analyze healthcare spending

On December 11, 2025, the financial officers for a number of states issued a letter requesting certain companies to undertake a detailed payment-integrity analysis of healthcare spending. The officers stated that they act as fiduciaries of public investment funds that hold shares in these companies, and they expressed an interest in “help[ing] you better manage and oversee your company’s healthcare spending.”

The states suggested a few steps, including the following:

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