Price Transparency Rules: A Florida Physician Guide 2026

Consider a scheduler in a Tampa orthopedic practice who tells a patient that a knee arthroscopy will cost $2,400. She is quoting the surgeon’s fee, and she is quoting it accurately. Three weeks after the operation the patient also receives a bill from the surgery center and a bill from the anesthesiologist, and he believes that he was told a price that was not true. As of last week, the Federal Trade Commission has said in writing that a quote of that kind may be a deceptive practice under federal law.

On October 5, the FTC sent warning letters about price disclosure to 24 large health systems. On the same day, federal agencies finalized a rule that will change the rate files that commercial insurers publish about their contracted physicians. Both actions affect how a Florida practice quotes its prices and how it negotiates with payers.

What the Agencies Did on October 5

The Centers for Medicare & Medicaid Services, together with the Departments of Labor and the Treasury, issued final rules updating the Transparency in Coverage requirements, which have required health plans and insurers to post their negotiated rates since July 2022. According to Becker’s Hospital Review, the rule takes effect December 5, and the first revised rate files are due April 1, 2027.

FTC Chairman Andrew Ferguson sent the warning letters the same day. The agency did not name the recipients, and its press release describes them as 24 of the nation’s largest healthcare services companies. The FTC stated that the letters are warnings and are not findings that any recipient broke the law. Holland & Knight reported that Chairman Ferguson has said the agency has already opened investigations into hospital price transparency.

What Changes in the Payer Files

The current payer files are difficult to use. They list a negotiated rate for nearly every provider and nearly every code, including services that the provider would never perform. Healthcare Dive gave the example of a psychiatrist’s rate for heart surgery. Medical Economics cited a peer-reviewed study of 61 insurers in which 91.8% of the published rates were of this kind.

Under the final rule, plans must exclude rates for providers who would not be paid for a service given their specialty, and they must publish the internal rules they used to make those exclusions. They must also publish a list of the providers who were actually paid for at least one claim. Rates will be organized by provider network instead of by individual plan, and each file will carry the network’s name. The files will be updated quarterly instead of monthly.

The rule adds accountability as well. Each plan must attest that its files are accurate and complete, and each file must name the chief executive, president, or senior official responsible for it. For out-of-network care, plans must report allowed amounts once they have 11 claims for a service, where the old threshold was 20. For plan years beginning on or after January 1, 2027, members can also request a personalized cost estimate by telephone.

What the FTC Said About Price Quotes

The letters rely on Section 5 of the FTC Act, which prohibits unfair and deceptive practices. According to the agency’s press release, a disclosure may be deceptive when it leaves out physician or facility fees or covers only part of the expected course of care, because the patient may reasonably believe that he has been told the total cost. The letters focus on routine, nonemergency care that is scheduled in advance.

The FTC also addressed the hospitals that already comply with the CMS price rules. The letters state, “The CMS rules do not create a safe harbor from FTC Act liability.” A hospital can post every required file and still mislead a patient with an incomplete quote on the telephone.

The 24 letters went to large systems. Epstein Becker Green reported that the letter template encourages “all healthcare-service providers” to review their price disclosures, and Holland & Knight reported that similar letters are going to other providers. I would not assume that a physician practice is outside the agency’s attention.

Why This Matters in a Florida Practice

Florida physicians already have a duty in this area. Under section 456.0575 of the Florida Statutes, a practitioner who is asked by a patient for an estimate before nonemergency services in a licensed hospital or ambulatory surgical center must provide a good faith estimate of anticipated charges within seven business days. Failure to provide it without good cause results in disciplinary action and a fine of $500 per day, up to $5,000. The federal No Surprises Act separately requires good faith estimates for uninsured and self-pay patients.

The physicians with the most exposure to the FTC’s theory are those whose fees are billed separately from a facility’s fee. That group includes surgeons, anesthesiologists, radiologists, pathologists, and employed physicians whose visits carry a hospital facility fee. In each case the patient hears one number and receives more than one bill.

The payer rule works in the physician’s favor. A Florida practice has rarely been able to see what Florida Blue or UnitedHealthcare pays a comparable practice in the same county. After April 2027 that information should be in a file organized by network, without the rates that made the old files unusable, and signed by a named executive.

What Florida Physicians Should Do Now

1. Compare your quotes with your bills. Take three scheduled procedures from the last quarter, find what the patient was told beforehand, and compare it with everything the patient was eventually billed by every party.
2. State in every estimate what it does not include. If your quote covers only your professional fee, say so in writing, and name the facility, the anesthesia group, and any laboratory or imaging provider that will bill separately.
3. Confirm that your office can meet the Florida deadline. A request for an estimate before a hospital or surgery center procedure starts a period of seven business days under section 456.0575, and your staff should know who answers it.
4. Review your process for uninsured and self-pay patients, who are entitled to a good faith estimate under the No Surprises Act when they schedule care.
5. Mark April 1, 2027 on your calendar. When the revised files are posted, find your own practice in each payer’s file, confirm that your rates are listed correctly, and compare them with similar practices before your next renewal. Our contract negotiation playbook describes how to use rate data in that conversation.
6. None of this constitutes legal advice, so ask a Florida health care attorney before you use public rate data in a negotiation, because independent practices that share or coordinate their rates with competitors can create an antitrust problem.

The Bigger Picture

Physicians have asked for years that insurers be held to account for what they publish and what they pay, and this rule moves in that direction. The same standard is now being applied to us. I think that is fair, and I think independent practices have the most to gain from it. An office that can state one complete price for a service, with no facility fee added later, has an advantage that patients will understand. The Florida Medical Association and our county societies should help their members prepare complete estimates before the FTC sends its next round of letters.

For more on what payers and health systems must disclose, see our coverage of the Medicare efficiency adjustment, the 2027 UnitedHealthcare network split in Florida and UnitedHealthcare’s October 1 prior authorization change. All of our reporting on this subject is collected in our guide to Medicare and payer changes for 2027.

Frequently Asked Questions

Did the FTC send price transparency warning letters to Florida physicians?

The FTC sent letters on October 5, 2026 to 24 large healthcare services companies and did not name them. The letters were directed at health systems. Law firms that reviewed the template report that it encourages all healthcare service providers to review their price disclosures.

Is it deceptive to quote only the physician’s fee?

The FTC’s position is that a price disclosure may be deceptive if it omits physician or facility fees and the patient reasonably believes it is the total cost. A quote that clearly states what it covers and who else will bill is the safer practice.

What does Florida law require when a patient asks for a price estimate?

Section 456.0575 of the Florida Statutes requires a practitioner to provide a good faith estimate of anticipated charges within seven business days when a patient requests one before nonemergency services in a licensed hospital or ambulatory surgical center. The fine for failing to provide it without good cause is $500 per day, up to $5,000.

When will the new insurer rate files be available to Florida practices?

According to Becker’s Hospital Review, the first revised in-network and out-of-network files are due April 1, 2027, and the new files that explain each plan’s exclusions are due October 1, 2027. The files will be updated quarterly.

This article was drafted with the assistance of AI writing tools, then reviewed, edited, and approved by Dr. Sean C. Orr, M.D., who holds full editorial responsibility for its content. The header illustration was created with AI image tools.

References

1. Centers for Medicare & Medicaid Services, “Transparency in Coverage Final Rules (CMS 9882-F)” fact sheet (October 5, 2026). cms.gov
2. Federal Trade Commission, “FTC Issues Letters Warning Hospitals Against Deceptive Pricing Practices” (October 5, 2026). ftc.gov
3. Becker’s Hospital Review, “CMS finalizes price transparency overhaul for payers: 6 things to know” (October 5, 2026). beckershospitalreview.com
4. Healthcare Dive, “Trump administration revamps insurer price transparency reporting” (October 5, 2026). healthcaredive.com
5. Holland & Knight, “Price Transparency Under the FTC Act: What Healthcare Providers Should Know” (October 8, 2026). hklaw.com
6. Epstein Becker Green, “Federal Trade Commission Sends Price Transparency Warning Letters to 24 Health Systems” (October 6, 2026). ebglaw.com
7. Medical Economics, Morning Medical Update Weekly Recap (October 9, 2026). medicaleconomics.com
8. Florida Statutes section 456.0575, Duty to notify patients. leg.state.fl.us
9. Centers for Medicare & Medicaid Services, No Surprises Act overview of rules and fact sheets. cms.gov