Abstract
Our study uses the latest Transparency in Coverage data to show that there is wide variation in health care prices for some of the most commonly utilized services in the United States. The findings demonstrate that there is an opportunity for employers, policymakers, and other stakeholders to curb health care spending by choosing cost-efficient health care networks and providers.
Interact J Med Res 2026;15:e96883doi:10.2196/96883
Keywords
Introduction
Health care prices in the United States have historically been hidden from the public hindering meaningful analysis of health care markets and prices. This matters because prices impact access to care and are a major driver of high health care spending [,].
The information landscape began to change with first price transparency rule, Hospital Price Transparency (HPT) in 2021 which required hospitals to disclose prices of a select set of services. Then, in 2022, the Transparency in Coverage (TiC) rule began to require insurers to release negotiated rates for all covered services.
These datasets have proven valuable in shedding light on variation in health care prices. HPT data has been used to demonstrate large variation in prices for urological procedures [], and radiology services [], among others. Recent studies have begun to exploit more comprehensive TiC data and show wide variation in prices for inpatient and outpatient services [], within hospitals for commonly provided services [], among others.
We assess the within-provider variation in prices for the top 20 most commonly services in an office setting and find that the average difference between the minimum and maximum rates is 40% of the national Medicare rate. Our results complement Wang et al (2024) study which examines within-hospital price variation for inpatient and outpatient services and finds that difference between minimum and maximum prices negotiated by hospitals to be 86% and 222% of Medicare rates, respectively [].
Methods
We downloaded the machine-readable files for the largest national payers (Cigna, Aetna, United Healthcare, various Blue Cross and Blue Shield plans) for the third quarter of 2025.
These files contain information on negotiated rates for all covered services along with identifying information on provider tax identification number (TIN), payer name and plan type.
We removed duplicates and ‘ghost rates’—negotiated rates corresponding to a provider for a service they are unlikely to ever bill for,—which are common in TiC data following the established methodology from published literature [].
This analysis focuses on the top twenty most commonly utilized HCPCS ((Healthcare Common Procedure Coding System) codes in an office setting (determined based on national Medicare data and Colorado and New Hampshire’s All-Payer Claims databases). To limit the influence of outliers, we exclude rates below the 1st percentile and above the 99th percentile for each billing code and restrict the sample to billing code–TIN combinations with at least two negotiated rates.
The analysis data consists of approximately 5.6 million negotiated rates for 20 HCPCS codes in an office place of service. shows the distribution of negotiated rates by billing codes.
| Billing code | Billing code description | Percentiles ($) | Standard deviation | Skewness | No. of negotiated rates | ||||
| 10th | 25th | 50th | 75th | 90th | |||||
| 36415 | Collection of venous blood by venipuncture | $1.80 | $2.91 | $3.00 | $5.50 | $8.21 | 2.52 | 1.16 | 252,841 |
| 80048 | Basic metabolic panel (BMP) | $4.23 | $5.19 | $6.77 | $9.31 | $12.82 | 3.56 | 1.44 | 129,614 |
| 80053 | Comprehensive metabolic panel (CMP) | $5.08 | $6.04 | $8.12 | $11.49 | $15.65 | 4.46 | 1.42 | 136,811 |
| 80061 | Lipid panel | $5.62 | $7.74 | $10.71 | $15.00 | $20.95 | 6.34 | 1.43 | 175,161 |
| 83036 | Hemoglobin A1c test | $4.67 | $5.70 | $7.77 | $10.85 | $14.86 | 4.24 | 1.42 | 183,042 |
| 84443 | Thyroid stimulating hormone (TSH) test | $7.06 | $9.65 | $13.44 | $18.28 | $25.36 | 7.49 | 1.34 | 148,063 |
| 85025 | Complete blood count (CBC) with differential | $4.63 | $5.44 | $6.29 | $8.70 | $11.96 | 3.15 | 1.47 | 187,763 |
| 85610 | Prothrombin time (PT/INR) | $2.61 | $3.00 | $4.29 | $5.50 | $6.93 | 1.72 | 1.22 | 145,974 |
| 88305 | Surgical pathology examination, moderate complexity (eg, biopsy tissue exam) | $40.94 | $53.50 | $71.84 | $102.59 | $131.49 | 41.50 | 1.43 | 42,117 |
| 90471 | Immunization administration (1 vaccine) | $12.00 | $14.72 | $19.63 | $26.80 | $33.82 | 9.01 | 1.02 | 211,824 |
| 93010 | Electrocardiogram (ECG/EKG) interpretation and report | $7.79 | $9.36 | $12.16 | $14.94 | $17.56 | 4.19 | 1.09 | 88,739 |
| 97110 | Therapeutic exercises (physical therapy), 15 minutes | $20.80 | $24.64 | $29.66 | $34.99 | $45.91 | 10.72 | 1.61 | 215,203 |
| 97112 | Neuromuscular reeducation, 15 minutes | $23.10 | $27.31 | $32.49 | $38.96 | $50.77 | 12.04 | 1.58 | 210,790 |
| 97140 | Manual therapy techniques (eg, mobilization), 15 minutes | $19.14 | $22.55 | $27.24 | $32.48 | $42.59 | 10.20 | 1.62 | 218,521 |
| 97530 | Therapeutic activities, 15 minutes | $24.93 | $29.71 | $36.50 | $43.32 | $56.53 | 13.60 | 1.46 | 145,810 |
| 98941 | Chiropractic manipulation, 3‐4 spinal regions | $24.43 | $30.65 | $40.53 | $54.19 | $66.18 | 16.63 | 0.77 | 55,689 |
| 99203 | New patient office visit, moderate complexity | $73.50 | $86.70 | $107.86 | $130.09 | $163.66 | 36.60 | 1.08 | 717,830 |
| 99212 | Established patient office visit, low complexity | $28.66 | $36.22 | $46.53 | $58.03 | $72.91 | 17.42 | 0.89 | 708,342 |
| 99213 | Established patient office visit, low-moderate complexity | $52.06 | $61.28 | $76.02 | $94.90 | $118.35 | 26.58 | 1.01 | 808,269 |
| 99214 | Established patient office visit, moderate complexity | $75.95 | $90.31 | $110.02 | $138.66 | $172.76 | 38.73 | 1.03 | 805,806 |
We first calculate the mean, median, minimum, and maximum rates at the provider TINs and billing code level. These represent the calculated measures of prices a provider is willing to accept across insurers for a billing code.
We then take the average of these estimates across provider TINs at the billing code level to calculate the mean, median, minimum, and maximum rate a provider is willing to accept for a billing code on average.
We define the range of rates as the difference between the average minimum and average maximum rates divided by the national Medicare rate for each billing code.
Ethical Considerations
This study is exempt from ethics review, as all data used is publicly available. The study uses data on health care prices released by insurers and does not involve any human subjects. It is thus exempt from institutional review board.
Results
shows the average mean, median, minimum, and maximum –negotiated rates for the top 20 billing codes. All four summary statistics are unweighted averages and represent the average of the respective summary statistics across all provider TINs at the billing code level. Out of the 20 billing codes, difference between the maximum and minimum rate is greater than or equal to 50% of the national Medicare rate for four billing codes - 80048 (Basic Metabolic Panel), 80061 (Lipid Panel), 85610 (Prothrombin Time), and 88305 (Surgical Pathology).
| Billing code | Billing code description | Mean | Median | Minimum | Maximum | Medicare rate | % (Max. Min.) ÷ Medicare | Standard deviation | Skewness |
| (averaged over provider TINs) | |||||||||
| 36415 | Collection of venous blood byvenipuncture | $4.36 | $4.29 | $3.18 | $5.64 | $9.09 | 27 | 2.52 | 1.16 |
| 80048 | Basic metabolic panel (BMP) | $7.97 | $7.88 | $5.94 | $10.14 | $8.46 | 50 | 3.56 | 1.44 |
| 80053 | Comprehensive metabolic panel (CMP) | $9.30 | $9.25 | $7.15 | $11.54 | $10.56 | 42 | 4.46 | 1.42 |
| 80061 | Lipid panel | $12.42 | $12.20 | $9.02 | $16.15 | $13.39 | 53 | 6.34 | 1.43 |
| 83036 | Hemoglobin A1c test | $8.55 | $8.48 | $6.70 | $10.49 | $9.71 | 39 | 4.24 | 1.42 |
| 84443 | Thyroid stimulating hormone (TSH) test | $14.97 | $14.97 | $11.21 | $18.76 | $16.80 | 45 | 7.49 | 1.34 |
| 85025 | Complete blood count (CBC) with differential | $7.72 | $7.60 | $6.03 | $9.61 | $7.77 | 46 | 3.15 | 1.47 |
| 85610 | Prothrombin time (PT/INR) | $4.61 | $4.36 | $3.41 | $6.16 | $4.29 | 64 | 1.72 | 1.22 |
| 88305 | Surgical pathology examination, moderate complexity (eg, biopsy tissue exam) | $75.08 | $74.35 | $54.11 | $97.22 | $69.54 | 62 | 41.50 | 1.43 |
| 90471 | Immunization administration (1 vaccine) | $19.42 | $19.38 | $15.04 | $23.87 | $20.05 | 44 | 9.01 | 1.02 |
| 93010 | Electrocardiogram (ECG/EKG) interpretation and report | $10.67 | $10.64 | $9.27 | $12.13 | $7.76 | 37 | 4.19 | 1.09 |
| 97110 | Therapeutic exercises (physical therapy), 15 minutes | $28.19 | $28.05 | $23.59 | $33.00 | $28.79 | 33 | 10.72 | 1.61 |
| 97112 | Neuromuscular reeducation, 15 minutes | $31.37 | $31.18 | $26.36 | $36.62 | $32.02 | 32 | 12.04 | 1.58 |
| 97140 | Manual therapy techniques (eg, mobilization), 15 minutes | $26.06 | $25.90 | $21.75 | $30.57 | $27.17 | 32 | 10.20 | 1.62 |
| 97530 | Therapeutic activities, 15 minutes | $34.68 | $34.43 | $28.86 | $40.79 | $34.61 | 34 | 13.60 | 1.46 |
| 98941 | Chiropractic manipulation, 3‐4 spinal regions | $39.45 | $38.50 | $30.83 | $49.27 | $38.49 | 48 | 16.63 | 0.77 |
| 99203 | New patient office visit, moderate complexity | $116.01 | $115.58 | $99.79 | $132.71 | $109.01 | 30 | 36.60 | 1.08 |
| 99212 | Established patient office visit, low complexity | $50.47 | $50.37 | $41.52 | $59.46 | $54.99 | 33 | 17.42 | 0.89 |
| 99213 | Established patient office visit, ow-moderate complexity | $83.27 | $83.02 | $70.93 | $95.93 | $88.95 | 28 | 26.58 | 1.01 |
| 99214 | Established patient office visit, moderate complexity | $121.03 | $120.60 | $103.78 | $138.77 | $125.18 | 28 | 38.73 | 1.03 |
aTIN: tax identification number.
Across the 20 billing codes, we find the average variation between the minimum and maximum rates to be 40 % of the Medicare rate (unweighted).
Discussion
Our assessment shows that providers negotiate a wide range of prices for the same service across insurers. Thus, the same provider can be low cost for one network but high cost for another network. Our findings that prices for commonly utilized services can vary by up to 40% of the Medicare rate in an Office setting compliments existing literature that documents substantial variation in prices across and within hospitals. This highlights the importance of the choice of network and benefit design in reducing health care spending. For employers, health plans, and policymakers, our findings demonstrate that choice of networks and providers can have a substantial impact on health care spending. Future work should aim to understand how navigating patients to lower cost providers can generate potential savings.
Acknowledgments
The authors acknowledge support for this study from the Peterson Center on Healthcare.
Artificial intelligence was not used in the creation of any portion of this manuscript.
Funding
Support for this work came from The Peterson Center on Healthcare.
Data Availability
The analysis in the paper is based on data released by individual insurers under the Transparency in Coverage price transparency rule. These datasets are publicly available on insurers' websites. The authors downloaded, cleaned, and validated the datasets from individual insurers' websites.
Authors' Contributions
Conceptualization: YP, DM
Data curation: YP, DM
Formal analysis: YP, DM
Funding acquisition: YP, DM
Investigation: YP, DM
Methodology: YP, DM
Project administration: YP, DM
Resources: YP, DM
Software: YP, DM
Supervision: YP, DM
Validation: YP, DM
Visualization: YP, DM
Writing – original draft: YP, DM
Writing – review & editing: YP, DM
Conflicts of Interest
YP and DM are employed at Simple Healthcare which works with price transparency data.
References
- Brot-Goldberg ZC, Chandra A, Handel BR, Kolstad JT. What does a deductible do? The impact of cost-sharing on health care prices, quantities, and spending dynamics. Q J Econ. Aug 1, 2017;132(3):1261-1318. [CrossRef]
- The role of prices in excess US health spending. Health Affairs Brief. Jun 9, 2022. URL: https://www.healthaffairs.org/content/briefs/role-prices-excess-us-health-spending [Accessed 2026-07-09]
- Gul ZG, Sharbaugh DR, Guercio CJ, et al. Large variations in the prices of urologic procedures at academic medical centers 1 year after implementation of the Price Transparency Final Rule. JAMA Netw Open. Jan 3, 2023;6(1):e2249581. [CrossRef] [Medline]
- Jiang JX, Forman HP, Gupta S, Bai G. Price variability for common radiology services within U.S. hospitals. Radiology. Mar 2023;306(3):e221815. [CrossRef] [Medline]
- Whaley C, Radhakrishnan N, Richards M, Simon K, Chartock B. Understanding health care price variation: evidence from Transparency-in-Coverage data. Health Aff Sch. Feb 2025;3(2):qxaf011. [CrossRef] [Medline]
- Wang Y, Xu J, Anderson G. Within-hospital price gaps across national insurers. JAMA Netw Open. Dec 2, 2024;7(12):e2451941. [CrossRef]
- Muhlestein DB. High prevalence of ghost rates in transparency in coverage data. Health Aff Sch. Nov 2025;3(11):qxaf212. [CrossRef] [Medline]
Abbreviations
| HCPCS: Healthcare Common Procedure Coding System |
| HPT: Hospital Price Transparency |
| TiC: Transparency in Coverage |
| TIN: tax identification number |
Edited by Matthew Balcarras; submitted 01.Apr.2026; peer-reviewed by David M Anderson, Rakibul Islam; final revised version received 17.Jun.2026; accepted 18.Jun.2026; published 23.Jul.2026.
Copyright© Yuvraj Pathak, David Muhlestein. Originally published in the Interactive Journal of Medical Research (https://www.i-jmr.org/), 23.Jul.2026.
This is an open-access article distributed under the terms of the Creative Commons Attribution License (https://creativecommons.org/licenses/by/4.0/), which permits unrestricted use, distribution, and reproduction in any medium, provided the original work, first published in the Interactive Journal of Medical Research, is properly cited. The complete bibliographic information, a link to the original publication on https://www.i-jmr.org/, as well as this copyright and license information must be included.

