Price Transparency as Infrastructure: Building Defensible Businesses on CAA Data

DISCLAIMER: The views and opinions expressed in this essay are solely my own and do not reflect the views, opinions, or positions of my employer, Datavant, or any of its affiliates.

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TABLE OF CONTENTS

Abstract

Introduction: The Accidental Infrastructure Play

What Actually Got Built: Understanding the Data Landscape

Getting Your Hands on the Data: A Practical Guide

The Business Model Playbook: What Works and What Doesn’t

The Enforcement Problem and Why It Matters

Future State: Where This Goes Next

Conclusion: The Window Is Closing

ABSTRACT

The Consolidated Appropriations Act of 2021 created a price transparency mandate that most people still don’t understand. Employers and health plans must now publish machine-readable files showing negotiated rates with every provider in their network. Three years into implementation, we have one of the most comprehensive healthcare pricing datasets ever assembled, and almost nobody is using it effectively. This essay examines what data actually exists, how to access it, which business models show early traction, and why enforcement inconsistency creates both opportunity and risk. For health tech investors, this represents a rare moment where regulatory infrastructure has been built but commercial applications remain nascent. The window for first-mover advantage is open but closing as larger players begin to recognize the asset they’re sitting on.

Introduction: The Accidental Infrastructure Play

So here’s the thing about the CAA price transparency requirements that nobody really talks about: they weren’t designed to create a new data infrastructure layer for healthcare. They were designed to shame health plans and employers into competing on price by exposing the absurd variation in what they pay for identical services. The theory was pretty straightforward - if you force plans to publish what they’re actually paying every provider for every service, market forces would kick in and prices would normalize. Employers would look at the data and realize they’re getting ripped off. Patients would shop around. Providers charging 10x what their competitor charges for the same MRI would have to justify it or lose business.