Brushing up on the state of healthcare price transparency in 2025

The push toward healthcare price transparency started in earnest nearly 15 years ago, when the ACA highlighted the need for greater insight into hospital pricing, and the premise of healthcare consumerism took hold alongside the rise of high-deductible health plans. And while it's no longer the headline-grabber it once was, healthcare price transparency remains a perennial topic of discussion—and debate—within the industry. It's also a good topic to revisit periodically precisely because it no longer dominates the headlines, even as progress continues quietly below the surface.

While opinions on many health care policy topics are divided along party lines (see the intense debate and negotiation prior to the passage of the OBBA, about which you can read more here), price transparency tends to garner bipartisan support. And it thus remains a steady target of reforms. In just the latest example, on July 17, Senators Robert Marshall (R-Kansas) and John Hickenlooper (D-Colorado) introduced the Patients Deserve Price Tags Act, which would require hospitals, ambulatory surgery centers, imaging centers, and labs to publicly report prices, negotiated rates, and costs for their services.

On the surface, the bipartisan appeal makes sense. Healthcare price transparency is a free market-friendly, light political lift (in the sense that it doesn't require huge amounts of new regulation), very American approach. In theory, price transparency enhances competition in healthcare by empowering consumers to shop for care and, in so doing, encouraging price convergence and competition.

Right? Well, not so fast. There's the theory, then there's the practice, and then there are the unintended consequences.

We dug into the latest, and here are three things to know about the state of healthcare price transparency in 2025

1. Policies promoting healthcare price transparency continue to quietly have an impact, with a heavier focus recently on ensuring/enforcing compliance.

The current administration is leaning into price transparency as a way of correcting information imbalances in health care. In February 2025, the White House released an executive order to shore up price transparency requirements. The latest EO requires the Treasury, Labor, and HHS Secretaries to act to:

• Enforce disclosing actual prices rather than estimates;

• Release guidance or regulations on making pricing information standardized and able to be compared across sites of care and plans; and

• Revise enforcement plans to ensure compliance.

This EO builds on a push from the previous Trump administration to encourage price transparency, including the Transparency in Coverage Rule requiring most health plans to list their prices and cost-sharing information to members. (There is an equivalent rule for hospitals—the Hospital Price Transparency Rule—that was implemented a couple of years earlier, also under the Trump administration.)

Initial implementation of the Trump administration rules was shaky, and enforcement has since been given more teeth (higher fines and increased automation to shorten delays in action against noncompliant organizations). The initial fines levied by CMS for non-compliance ($300/day) were not primary drivers of acquiescing to the new rules, according to at least one study of key informant interviews.

How will this latest EO change things? That remains to be seen, since (as is typical for an EO) it leaves much of the interpretation to the three agencies. It is possible that they will move to make the price transparency data easier to interpret (via the push for standardization) and beef up oversight and enforcement. This could also hasten the implementation of rules around posting prescription drug prices, too, which have been stalled since 2021.

CMS issued a request for information (with a deadline of July 21) on how CMS can support improving hospital price transparency compliance and enforcement., which may offer some rules as to what tighter enforcement could look like. While a summary of the comments isn't available yet, a handful of organizations (including the American Hospital Association, the Association of Academic Medical Centers, and the Healthcare Financial Management Association) have made their responses public. We've summarized the public comments we found below.

Key themes include:

• Recommendations to move beyond the format of the data (i.e. machine-readable files) to the actual content of the data. Many respondents emphasized the need for additional context on procedure volumes, confidence around accuracy, etc. in order to be able to better interpret the data.

• Universal agreement among the users of the data (employers, vendors, consumer advocacy groups, etc.) around the need for tighter enforcement, not only in the form of higher monetary penalties, but stricter/more specific deadlines for updating the data, and more publicity around non-compliant organizations.

2. Most consumers are still not shopping for care (despite a stated willingness to) for all the typical reasons we've come to understand.

Healthcare price transparency is first and foremost about consumer empowerment, so: 1) Is this information that consumers want? 2) Do they know how to use it? Answers: 1) Yes (with the caveat that this isn't the sole or even necessarily the deciding factor in where patients ultimately receive care); 2) Not really.

There's evidence that the public supports the concept of healthcare price transparency. A 2023 McKinsey survey indicated that nearly 90% of Americans are willing to shop for at least one category of care.

Willingness to shop based on price does not seem to be as tied to action as one might expect. A Pioneer Institute survey of Massachusetts residents with employer-sponsored health insurance—Massachusetts has had price transparency legislation in place for years—found that 70% of consumers would like to know the cost of a procedure before they have it, but only about 20% have actually tried to find the price of a service before receiving it. This is due, in part, to lack of awareness—a significant majority of respondents didn't know whether their insurance company had a cross estimate or price comparison tool.

Evidently, price transparency isn't a cure-all. The original assumption—that free-market thinking can be readily applied to health care—is flawed for several important reasons.

In emergency situations, consumers can't comparison-shop.

It makes sense—when you realize at the airport that you forgot your toothbrush or deodorant, you'll pay the marked-up sticker price at the convenience store near your gate. That said, the prospect of emergencies is not a reason to abandon price transparency efforts altogether—McKinsey estimates that close to three-quarters of commercial claims spending is for care that could be shoppable (i.e., non-emergency and where a patient has a choice of providers and setting). Interestingly, this represents a considerable increase from earlier estimates by other organizations. For instance, in 2016 the Health Care Cost Institute estimated that a maximum of 43% of individual health care spending (by patients under 65 with employer-sponsored insurance) was on shoppable services.

Further, while not an emergency in the conventional sense, a new complex diagnosis can throw someone for a loop, and in such a case he or she will likely feel overwhelmed and inclined to rely on advice from a resource like a care navigator rather than be guided by cost considerations. Patients feeling overwhelmed was cited as a barrier to shared decision-making by more than half of cancer care providers consulted in a survey, indicating that care navigation support, rather than reviewing list prices for specific treatments, becomes a priority.

A lay consumer—even a health economist—will have a hard time knowing what his or her bill is likely to be.

Once an individual arrives at the appointment, he might find out that he needs additional services that he didn't account for, such as a screening test necessitating additional exploratory procedures. While healthcare price transparency is, at least in part, a mechanism for empowering individual consumer choices, one analysis notes that the way prices are listed is more suited to industry insiders: "While listing master charge, commercial, and cash prices is helpful, what would be more helpful to consumers is if they better understood what their out-of-pocket costs will be for a service given their particular form of insurance." In addition, actually comparing prices across facilities can be difficult for a handful of reasons laid out in a KFF analysis: estimates don't always include professional fees on top of facility fees; hospitals don't always clarify the difference in price when getting a procedure on an outpatient or inpatient basis; and price can be presented as an estimate (which can change quickly), average, or single rate. (This year's executive order is meant to encourage moving away from providing estimates.)

The healthcare price transparency data itself is also not exactly perfect. An early review of the data found a range of issues that complicate its usability for researchers (such as rates listed for services that providers do not or cannot provide; different methods for rate calculations producing inconsistent results; and lack of unique identifiers for some hospitals), making it even more tricky for consumers who don't specialize in this topic. Even proactive patients are encountering unexpected bills in the wake of expanded price transparency. A recent KFF Health News piece used the example of a patient who received an estimate in advance for her mammogram and sonogram ($359)—which she paid—only to then be billed for an additional $1,677.51. The negotiated rate for the procedure based on the master price list the hospital was required to publish was set at $302.56, entirely inconsistent with what she was billed and even with the out-of-pocket payment requested up front.

Cost is not the sole driver of decision-making.

The 2023 McKinsey survey found that quality was the most important factor in choosing a provider for 15% of respondents, followed by provider location (10%), and then timing of available appointments was ranked even with estimated out-of-pocket costs (9% each). Quality data itself can be difficult to parse, and patients might (perhaps erroneously) view higher sticker price as indicative of higher quality. Plus, patients will be taking an array of values into account as they make decisions about their care—cost may be one of them, but there are other decision-relate d values and external values that factor in, too, like side effects of recommended treatments and advice from family and clinicians. Augmenting effective price transparency with accurate and up-to-date information about quality and provider networks might enable better decision making and, in so doing, create more competition in the market.

Could this change in the future?

While nearly 2/3 of Americans reported not having shopped for health care based on price in a survey conducted by AKASA on behalf of YouGov, younger adults (18-34) were more likely to research prices at 45% than 55+ adults at 27%. So, maybe there's a new trend, or maybe younger health care consumers are just more price sensitive. Still, we remain skeptical given all of the reasons listed above—there's not too much reason to think younger consumers will be more immune to these challenges than older ones.

Does that mean that transparency isn't having ANY effect? Well, not so fast...

3. There's some evidence to suggest that plans and providers are using greater transparency to shift prices, though in which direction remains a source of debate (and perhaps varies by region).

Perhaps counterintuitively, price transparency risks facilitating price increases. Price transparency can be a powerful negotiating tool for health plans—if they see that other plans are getting better negotiated rates, then they have a better bargaining position. That negotiation can result in higher prices in concentrated health care markets: According to a report from the California Health Care Foundation, one possible scenario is "shadow pricing," where a provider that realizes it is receiving a lower rate than a competitor raises its prices to match. Active oversight and antitrust safeguards could minimize the risk of this scenario coming to fruition—the oft-cited warning example comes from Danish concrete prices in the 1990s, when the government antitrust authority published prices for certain kinds of concrete in three Danish regions and subsequently saw average prices increase by 15-20% in a year.

There does seem to be some recent movement in prices. An analysis from Turquoise Health found that, between December 2021 and June 2024, negotiated rates began to come together, so prices at the high end are being driven down and at the low end are being pulled up, a point in favor of greater transparency. Perhaps these differing findings have to do with the markets represented in analyses—Turquoise Health admits to their findings not necessarily being applicable to rural areas—or different methodologies. The Turquoise Health analysis looks at prices longitudinally rather than as a point-in-time snapshot.

Takeaways and what we're watching next

Price transparency is a significant, and, at minimum from a regulatory standpoint, essential move in the current healthcare system. Hospitals that have until now been dragging their feet on compliance with the regulations will likely find that to be an untenable approach going forward. That said, there is more to be done to empower consumers to shop for care, such as making both price and quality data findable, understandable, and actionable. And we're perhaps most interested in keeping an eye on how other entities—plans, providers, employers, etc.—are using the data as it becomes more readily available, and more useable.

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