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Updates: CMS v1 Data Schema Locked for MRFs
by Jill Dornan 
March 7, 2022 On March 1, CMS locked the v1 data schema for machine-readable files (MRFs) under the Transparency in Coverage mandate. At the very last minute, CMS made significant changes around support for rate types and custom billing codes. Watch this video for HealthSparq’s quick summary of the latest updates.
Time is of the essence for health plans to ensure they understand and enact the requirements before CMS starts MRF enforcement on July 1, 2022. Let’s quickly walk through the biggest changes from CMS for the v1 data schema:
Change 1: Support for additional rate types
The Transparency in Coverage final rule made it clear that all negotiated rates should be represented in dollars in the MRF data schema. Despite the growing interest in value-based care, however, there is still widespread use of percent of billed care. The dollar value requirement puts the burden on plans with alternative payment arrangements to come up with the dollar amounts for the file. The final changes for the v1 schema allows two new negotiation types: percentages and per diem. This change allows plans to include a percentage rate rather than a negotiated rate for a percent of billed charge contract arrangement.
As of now, CMS has indicated this is only for percent of charge contracts. Other contract arrangements, such as reference-based pricing, still require a dollar amount. For per diem rates, the health plans can also now list the per diem, as a dollar amount, for the service that the plan has agreed to pay with an in-network provider.
Change 2: Ability to add custom billing codes
Some plans may have their own billing code requirements. CMS added a new code type within the billing code fields that will allow plans to share data that isn’t included in standard code types. This provides plans with greater flexibility in sharing data publicly.
Change 3: Adding new, custom information
When it comes to negotiated rates, there is a lot of nuance and information to share. CMS just added a new open data field for plans to share additional information to provide greater clarity around the data included in the files.
CMS made previous modifications to the data schema to address the challenge of very large file volume and file sizes. The changes, such as the ability to link to external MRFs, help make the files smaller than the original schema. However, there are still concerns about downloadability given the estimated file sizes.
The final schema changes raise additional questions for plans on compliance and CMS will be holding a webinar on March 16 to provide additional insights. You can also follow the conversations on the GitHub repo.
HealthSparq has been recommending data schema changes to support plans and their compliance needs, and updating our support for all items and services to support price transparency with our HealthSparq One platform. Our team is here to help your team on your path to price transparency compliance. Reach out to us to learn more.