Schema 2.0 Readiness for TALON MRF Clients
How TALON Supports Compliance
Provider groups are defined once and referenced throughout pricing files, eliminating redundancy to reduce file size.
Entity Resolution Controls
When EINs are disclosed, TALON ensures corresponding business names are included and validated, improving accuracy and defensibility.
Audit-Ready Output
All Schema 2.0 files are generated through repeatable, validated processes with logging to support regulatory inquiry and audit response.
What Clients Should Expect
As a TALON client, you can expect a seamless transition to Schema 2.0 with comprehensive support at every stage. Our commitment to operational excellence ensures that your compliance requirements are met without disruption to your existing workflows.
Ongoing production of compliant machine-readable files throughout t transition period.
No additional operational burden associated with Schema 2.0 adoption.
Complete audit-ready documentation supporting all Schema 2.0 disclosures for regulatory confidence.
Bottom Line
Incremental Refinement
Schema 2.0 represents an incremental but important refinement of Transparency in Coverage requirements.
TALON Is Prepared
TALON is fully prepared to support this transition seamlessly on behalf of its clients.
Clients that rely on TALON for MRF production can be confident that Schema 2.0 compliance will be delivered as part of TALON's ongoing service without disruption, rework, or last-minute implementation risk. Our platform's robust architecture and proven compliance capabilities operational efficiency.
Client FAQ: Transparency in Coverage Schema 2.0
Transparency in Coverage Schema 2.0
What is Transparency in Coverage Schema 2.0?
Schema 2.0 is the next version of the technical specifications that govern how in-network negotiated rates and out-of-network allowed amounts are structured and published in Transparency in Coverage machine-readable files. It was announced by the Departments of Health and Human Services, Labor, and the Treasury in FAQs About Affordable Care Act Implementation Part 70 (May 22, 2025). Schema 2.0 focuses on reducing file size, eliminating redundant data, and improving clarity and usability of disclosures. It does not expand the scope of data plans are required to disclose.
Do I need to do anything to prepare for Schema 2.0?
No. For clients that rely on TALON for MRF production, no action is required. TALON will manage the Schema 2.0 transition as part of its existing services, including updates to file structure, validation logic, and publication processes.
Will Schema 2.0 require changes to our current workflows or data feeds?
No. Schema 2.0 does not require clients to redesign internal data pipelines, submit new data types, or modify existing workflows. Any required changes will be handled within TALON’s platform and compliance processes.
Will our current MRFs remain compliant during the transition period?
Yes. Until Schema 2.0 enforcement begins on February 2, 2026, plans and issuers are expected to continue complying with Schema 1.0. TALON will ensure that all client MRFs remain compliant throughout the transition period and will coordinate the move to Schema 2.0 in advance of the enforcement date.
Will Schema 2.0 affect how our files are hosted or accessed?
No client action is required. TALON will continue to host and publish MRFs in accordance with CMS accessibility and availability expectations. Schema 2.0 is designed to improve usability for downstream users without changing access requirements.
Will Schema 2.0 increase regulatory or audit scrutiny?
Schema 2.0 reflects the Departments’ stated goal of making Transparency in Coverage data more usable and reviewable. TALON’s compliance framework is designed to support audit-ready documentation and regulatory inquiries should they arise.
Who should I contact if I have questions?
If you have questions about Schema 2.0 or your Transparency in Coverage disclosures, please contact your TALON Customer Success Manager.