Transparency may compel some healthcare providers to critically assess how their pricing holds up under public and competitive scrutiny especially where their charges are far in excess of the median for the same services in the same location. Transparency may also enable other health care providers to identify an opportunity to increase their prices where their charges are less than the median. A study by Turquoise Health showed convergence of prices where providers who have the highest prices reduced rates and those with the lowest prices increased rates – so that prices for the same service are becoming more similar across providers. That study observed that trend across 82.8% of the markets studied.

Similarly, a study by FAIR Health suggests that, after the No Surprises Act, an ever larger percentage of claims are “in-network” – with perhaps the exception of providers of mental health and substance use disorder services - increasing the percentage of medical expenses subject to the lower PPO point of purchase cost sharing. In-network providers will likely use this increased utilization in their bargaining over future fees.


Employers, particularly those managing self-insured plans, will use this transparency to benchmark fees, flag excessive markups and pursue reference-based pricing strategies. Healthcare professionals leading payer negotiations must be ready to justify cost variations and engage with more informed, data-driven employer partners.

Additionally, the order may reshape employer-provider relationships by increasing demands for value-based care arrangements. Transparent pricing makes it easier for employers to spot cost discrepancies between different care settings—such as hospitals versus ambulatory surgery centers—and question whether higher costs align with measurable clinical value.

As a result, providers may be required to reassess site-of-care pricing, defend higher-cost settings based on quality outcomes or collaborate with employers to develop shared savings models. Healthcare professionals should anticipate closer scrutiny of referral patterns, particularly in vertically integrated systems where financial and care delivery interests intersect.

Opportunities to strengthen care delivery and cost management
Healthcare professionals are well-positioned to turn price transparency mandates into actionable strategies that improve both care delivery and financial management. Operational leaders can use newly disclosed pricing data to analyze internal cost structures, pinpoint inefficiencies and maintain competitive pricing.

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