On July 22, 2025, the Centers for Medicare & Medicaid Services (CMS), along with the Departments of Labor and Treasury, hosted a webinar introducing Schema 2.0 for the Transparency in Coverage (TiC) Machine-Readable Files (MRFs). This update highlights what Zelis learned during this webinar.

The webinar included important changes to how provider group data and service codes are reported, with the goal of improving efficiency and reducing file sizes. The Department of Health and Human Services (HHS) intends to finalize Schema Version 2.0 on October 1, 2025, with enforcement beginning February 2, 2026.

Key Changes in Schema 2.0

Provider Group Reporting

  • Current (v1.0): Allowed three methods — inline, internal and external references.
  • Future (v2.0): Only internal provider group references will be permitted.
    • Inline and external references will be removed from the schema.
    • Internal referencing allows reuse of provider group definitions across negotiated rates, reducing duplication and improving file structure.
    • Example: One issuer reduced file size from 107.48 MB to 1.97 MB by switching to internal references. 

    Custom Place of Service Code

    • When negotiated rates are not impacted by service location, a custom code “CSTM-00” can be used.
    • This simplifies reporting for professional services by avoiding unnecessary listing of all service codes. 

    Implementation Implications

    • Organizations must restructure their MRFs to comply with internal-only provider group referencing.
    • Developers should prepare for schema validation updates and ensure systems can handle the new format.
    • The use of place of service (POS) code “CSTM-00” should be applied where service location does not affect pricing.

    Resources