Payer price files: the index vs the actual data

Health plans publish machine-readable price files and an index that points to them. We track 6,624 of those files across 109 issuers. Every index we fetch loads. About one in twelve of the data files behind them does not. Nearly all of the breakage comes from twelve issuers.

By Brett Spain · Published September 22, 2026 · Last updated September 22, 2026

The short version

A health plan has to publish its prices in a machine-readable file.

Most plans also publish an index. The index is a list of links. Each link points to a file with the actual prices in it.

We fetch both. The index nearly always works. The files it points to are a different story.

What a payer actually publishes

There are two required files under the federal transparency rule.

One holds in-network negotiated rates. The other holds out-of-network allowed amounts. The CMS technical guide is plain about it:

"There are two required machine-readable files associated with Transparency in Coverage:"

A third file is optional. It is the table of contents, and it is the index we described above. The CMS price transparency guide explains that it exists to stop payers repeating the same rates in many files.

So the index is a convenience, not a legal requirement on its own. That matters for how you read the numbers below.

What we did

We keep a running fetch of every price file URL we can find.

We started on 2026-07-31 and have fetched continuously since. As of today the archive holds 302,910 fetch attempts against 6,624 file URLs from 109 issuers.

We record the HTTP status every time. We count a file as reachable if it returns 200 or 304. A 304 means "not modified", which is a normal, healthy answer to a repeat request.

The index loads. The data files often do not.

Here is the finding, using the most recent fetch of each file.

Of 6,590 file URLs with at least one fetch, 6,061 are reachable right now. That leaves 529 that are not, or 8.03% of the total.

The split by file type is the interesting part.

Every single index loads. Not one of the 109 failed.

The files those indexes point to fail at rates between one in fifty and one in four. The in-network rate files are the worst, and those are the ones that hold the negotiated prices.

Why the rate files matter most

A provider file lists who is in the network. A drug file lists medicines.

The in-network rate file is the one that answers "what does this plan actually pay for this service". It is the file most people are looking for when they go looking at all.

It is also the file with the highest failure rate in our archive, at nearly one in four.

This is not an industry-wide problem

This is the part that surprised us.

All 529 unreachable files belong to just 12 of the 109 issuers we track. The other 97 issuers have no broken links at all.

So the headline "8% of price files are broken" is true and also misleading. It is not a diffuse industry failure. It is a small number of payers with a maintenance problem.

The worst offenders

Five issuers account for most of it. We identify them by HIOS issuer ID, which is the public identifier on their filings.

Two of these publish an index in which almost nothing resolves. For issuer 73751, 122 of 123 listed files do not load.

The state column comes from our own plan filings data, matched on issuer ID.

How long the broken links stay broken

A link that breaks for an hour is a blip. A link that breaks for three weeks is a broken promise.

We can tell the difference, because we have the fetch history for each URL.

Of the 529, 289 return a hard 404. Another 234 return nothing at all — the request fails before a status code comes back. The remainder return some other error.

Sixteen files have never once loaded. They were published as links and have never resolved to anything.

What the rule actually requires

The Transparency in Coverage final rules were issued in November 2020, at 85 FR 72158.

On public access, 45 CFR 147.211(c)(1) requires the files be:

"Made available on an internet website that is publicly available and accessible free of charge and without conditions …"

On refresh, 45 CFR 147.211(c)(3) requires they be:

"Updated monthly, and clearly indicate the date the file was most recently updated."

The CMS technical guide adds the re-use standard:

"These machine-readable files must be made available to the public without restrictions that would impede the re-use of that information."

We are not lawyers and this post is not a compliance opinion. We are reporting what the files did when we asked for them.

Why a 404 matters more than it sounds

A missing file is not only a missing file.

If you are comparing plans, a broken rate file means that plan's prices are absent from any comparison built on this data. The plan does not look expensive. It looks like nothing at all.

That is worse than a high price, because a gap is easy to mistake for a good result.

What to do if the file you need is missing

A few things are worth trying before you conclude the data does not exist.

Check the index again, because payers do move files and update the list. Try the issuer's transparency landing page directly. Check whether the file is listed under a different plan year.

If it still does not load, note the date you tried. A file that has been dead for three weeks is a different conversation from one that failed once.

What this does not tell you

We want to be clear about the limits here.

We are measuring whether a URL returns a file. We are not measuring whether the file inside is correct, complete, or current. A file can load perfectly and still hold stale or wrong prices.

We also only see the URLs we have found. If a payer publishes files we have not discovered, they are not in these counts.

And 8.03% is today's number. It moves as payers fix and break things.

Where these numbers come from

Every figure in this post comes from our own fetch archive, queried live on the day of publication.

• Source: our mrf_fetches and mrf_sources tables
• Extraction window: 2026-07-31 through 2026-09-22
• Records behind this page: 302,910 fetch attempts across 6,624 file URLs from 109 issuers
• Reachability basis: the most recent fetch per URL; HTTP 200 or 304 counts as reachable

Issuer state labels are matched from our plan filings data on HIOS issuer ID. External requirements are cited to the Federal Register text of the Transparency in Coverage final rules and the CMS price transparency technical guide.

Questions people ask

How many payer price files are currently unreachable?

In our archive, 529 of 6,590 tracked file URLs are unreachable on their most recent fetch. That is 8.03%. The figure covers 109 issuers and was measured on September 22, 2026.

Are the price file indexes reliable?

Yes, in our data. All 109 index files we track returned a good response on their most recent fetch. The failure rate for indexes is zero. The problem is the files they link to.

Which type of price file breaks most often?

In-network rate files. Of 431 tracked, 104 were unreachable, a rate of 24.13%. Provider files fail at 7.67% and drug files at 2.03%.

Is this a problem across the whole industry?

No. All 529 broken files come from 12 issuers. The other 97 issuers we track have zero broken links. It is concentrated, not general.

How long do broken price file links stay broken?

The currently-broken files have been failing for 7.0 days on average. The longest has been broken for 23 days. Sixteen files have never returned a good response at any point.

What does a 304 response mean?

It means "not modified". The file has not changed since we last fetched it, so the server tells us that instead of resending it. We count 304 as reachable because it is a healthy answer.

Are payers required to publish a table of contents file?

Not in general. The CMS guide lists the table of contents as optional. It becomes necessary when a payer groups multiple plans into one file. The two required files are in-network rates and out-of-network allowed amounts.

How often are payers required to update these files?

Monthly. 45 CFR 147.211(c)(3) requires the files be updated monthly and that they clearly indicate the date they were most recently updated.