Price transparency as pricing reform in a fee-for-service healthcare system aims to empower consumers by providing cost information so that they can shop for low cost, high value care and drive providers to lower healthcare prices through free market competition. Price transparency was codified as the Transparency in Coverage federal rule in 2020 after a lengthy public comment period that collected feedback from stakeholders across the provider, payer, administrative, and patient populations. This study analyzes price transparency as pricing reform in American healthcare by conducting a systematic literature review on price transparency in healthcare and following the federal rulemaking process through the proposed rule, Federal Register comments, and the final Transparency in Coverage rule. Recurring themes in the comments such as forced disclosure of proprietary trade secrets, patient needs, administrative burden to health plans and providers, and the roadblocks to more substantial pricing reform, are presented in a narrative synthesis. After analysis, the study has three key findings: 1) the public comment period of the rulemaking process has the potential to collect feedback from interest groups but may be inaccessible to patients, 2) the Transparency in Coverage rule will allow for greater access to data that will allow patients to budget for medical care and researchers to reveal industry trends and practices, and 3) the rule specifically and price transparency generally face pitfalls as pricing reform by potentially masking implementation challenges, lacking generalizability, and an unfairly assigning cost-cutting burden to patients. Policy takeaways include improving patient education, outreach, and engagement in the federal rulemaking process, better understanding the benefits and consequences of a proposed rule through pilot programs before national implementation and regulating healthcare prices from the top-down rather than relying on consumers with limited power and resources to drive down costs.
