The Transparency in Coverage Rule, implemented in July 2022, requires health plans to publish machine-readable files (MRFs) containing negotiated reimbursement rates.¹ While initially viewed as a step toward openness, the true value of these datasets is only now being realized through the application of artificial intelligence.
Using AI-powered analysis of MRF data across Arizona, a clear and consistent pattern has emerged: Doctors of Chiropractic (DCs) are reimbursed significantly less than other provider types for identical billing codes. This is not an isolated finding. It is consistent across payers, regions, and contract structures.
Even more concerning is what the data reveals about how these rates are established. Across thousands of contracts, there is almost no meaningful variation in reimbursement rates within the chiropractic provider class. From a statistical standpoint, this level of uniformity is incompatible with the concept of individualized, good-faith negotiation. Instead, it strongly suggests the use of standardized, externally imposed pricing models.
When expanded nationally—across hundreds of thousands of provider contracts—the pattern holds. The same suppressed reimbursement, the same lack of variance, and the same structural consistency appear across multiple TPAs and networks. This is not market behavior. This is system design.
These findings raise serious questions regarding compliance with existing legal and regulatory standards, including ACA Section 2706(a) provider nondiscrimination, as well as broader expectations surrounding fair contracting and network adequacy.
The implications extend beyond providers. Suppressed reimbursement discourages participation, restricts access to conservative, non-pharmacologic care, and disproportionately impacts Medicare and Medicaid populations—those who can least afford reduced access.
For years, these concerns were difficult to prove. Now, they are not.
AI has transformed raw transparency data into actionable evidence. The question is no longer whether inequities exist—it is whether we are willing to address them.
The AAC Reimbursement Fairness Committee has been formed to do exactly that. By integrating regulatory frameworks, AI-driven analysis, and coordinated advocacy, we are building a strategy to confront these practices directly and effectively.
This will require participation.
We need providers willing to engage, to share data, to support advocacy efforts, and to stand for fair and lawful reimbursement.
Now is the time to act.
We are asking Arizona chiropractors to:
To join this team, please reach out to our committee member Dr. Jeff Trinka, DC, at JeffTrinka@gmail.com and tell him you want to participate. He will take it from there.
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