CMS Hospital Price Transparency

An integrated, AI-powered solution supporting your organization's internal implementation of federal price transparency requirements.

Introduction

The CMS Hospital Price Transparency Rule requires hospitals to publish their standard charge information in both:

  • A Machine-Readable File (MRF), and
  • A consumer-friendly display or price estimator for shoppable services.

These requirements can involve extensive operational work, including data consolidation, formatting, mapping, and ongoing maintenance. They also present an opportunity for hospitals to understand pricing variation, strengthen rate strategies, and improve visibility into their managed care performance.

PayerAnalytics delivers an integrated solution that supports your organization's internal workflow for preparing CMS-aligned pricing files, organizing remittance data, and powering consumer-facing shoppable services. Our platform is designed to help hospitals streamline operational activities, reduce manual steps, and enhance data-driven insight.

This page summarizes publicly available CMS materials and is intended for informational purposes only. This content does not interpret regulatory requirements or constitute legal or compliance advice. All implementation approaches should be reviewed with your organization's compliance and legal teams.

Key Dates and Regulatory Updates

Current Requirements

Hospitals must publicly provide:

  1. A CMS-aligned Machine-Readable File (MRF)
  2. A consumer-friendly shoppable services display (or compliant price estimator)
  3. A footer link to the hospital's price transparency page
  4. A TXT file in the root folder for CMS automated retrieval

New Requirements for 2026 (CY 2026 OPPS/ASC Final Rule)

Beginning January 1, 2026, hospitals will be expected to include additional pricing-related elements for payer-specific negotiated charges that are based on percentages or algorithmic methodologies. These include:

  • Median allowed amount
  • 10th percentile allowed amount
  • 90th percentile allowed amount
  • Count of allowed amounts used to calculate these values
  • Updated attestation requirements and naming of a responsible official
  • Reporting of applicable organizational Type 2 NPIs

CMS references a 12–15 month lookback period for producing the required allowed-amount values.

Enforcement begins April 1, 2026

These elements will be subject to CMS enforcement beginning on this date.

Implementation Considerations

Producing complete, accurate, and CMS-aligned pricing files involves cross-departmental work, including:

  • Consolidating charge and remittance data
  • Mapping ERA/835 payment records to standard charge identifiers
  • Generating the percentile-based allowed amounts
  • Aligning files with CMS templates (CSV tall/wide, JSON)
  • Organizing metadata and structural elements
  • Maintaining attestations and required fields
  • Refreshing the shoppable services display
  • Managing publication and ongoing updates

An effective implementation requires a clear process, consistent data structure, and repeatable workflows.

Newly Published CMS Resources Supporting the 2026 Changes

CMS has recently updated several public resources that support implementation of the CY 2026 changes:

Updated MRF Templates

CMS has refreshed its templates (CSV tall, CSV wide, and JSON formats) in the publicly available GitHub repository. The templates include updated fields that correspond to the 2026 requirements.

Updated Online Validator

The CMS Online Validator now allows hospitals to select which version of the Hospital Price Transparency requirements to validate against, including the version aligned with the 2026 changes. Earlier versions from 2025 and 2024 remain available as archived references.

TXT File Generator and File Naming Wizard

These CMS tools continue to be available to help structure associated files in the required layout.

Enforcement Update: Civil Monetary Penalty (CMP) Reduction Option

CMS finalized a policy that allows a 35 percent reduction in the civil monetary penalty (CMP) in certain circumstances if a hospital accepts CMS's penalty determination and waives its right to an Administrative Law Judge (ALJ) hearing. CMS stated that this reduction does not apply to "core" requirement violations, including situations where required MRF information or shoppable services are not made public. This represents an enforcement policy update and does not change the underlying transparency requirements.

How PayerAnalytics Can Help

PayerAnalytics is an integrated, AI-powered solution purpose-built to support the operational work associated with Hospital Price Transparency requirements. Whether handled internally or supported by a partner, having a clear and repeatable process can support the implementation of the 2026 updates. Our platform enables hospitals to reduce manual burden, strengthen internal data workflows, and gain visibility into their pricing information.

Your organization maintains full control of validation, review, governance, and publication of all materials and disclosures.

AI-Driven MRF Solution

Our solution supports your MRF-related workflow by providing:

  • AI-driven ingestion and normalization of pricing and remittance data
  • ERA/835 processing that supports generation of median, 10th percentile, 90th percentile, and count values
  • Automated structuring aligned with CMS-published templates
  • Consolidation of metadata and field mapping
  • Export-ready datasets for internal validation and publication

This component helps reduce manual file handling, data mapping, and spreadsheet-driven processes.

Claims-Only Support

For organizations that manage most HPT activities internally but need help with remittance-based calculations, we offer a focused service that includes:

  • Extraction and normalization of ERA/835 remittance information
  • Calculation of allowed-amount values referenced in the CY 2026 rule
  • Mapping payment data to standard charge identifiers
  • Delivery of structured allowed-amount datasets ready for integration into your MRF workflow

This component helps teams incorporate remittance-based data elements without redesigning internal infrastructure.

Shoppable Services SaaS

Our hosted solution creates the consumer-friendly shoppable services display directly from the MRF:

  • Clean, modern, intuitive interface
  • Hosted and maintained by PayerAnalytics
  • Minimal IT involvement required

This component supports your organization's consumer-facing transparency display.

Solution Component: Rate Benchmarking & Insights

PayerAnalytics also provides analytics based on publicly available payer and hospital files. These insights can help internal teams identify:

  • Pricing variation across services or payers
  • Potential opportunities for optimization
  • Peer comparisons
  • Market trends and regional patterns

These analytics supplement your managed care, contracting, and revenue cycle teams with data-driven context.

Why AI Helps

Our platform uses machine learning to support operational efficiency by:

  • Identifying potential inconsistencies
  • Highlighting data patterns for review
  • Reducing manual, spreadsheet-based work

These capabilities complement internal compliance and legal review.

Civil Monetary Penalties

CMS may impose Civil Monetary Penalties (CMPs) for non-compliance with Hospital Price Transparency requirements. Based on publicly available CMS materials:

  • Smaller hospitals (30 or fewer beds): Penalties are generally calculated on a per-day basis and can reach significant annual amounts.
  • Larger hospitals: Penalties may be calculated per bed per day and can reach substantial annual totals.
  • Public posting: CMS may publicly post the names of hospitals that are out of compliance, which can have reputational implications.

CMS policies and penalty structures can change over time. Hospitals should rely on the latest CMS materials and consult with their compliance and legal teams for current details.

Example of Shoppable Service Information

An example of how pricing information can be displayed in a consumer-friendly format.

Similar info can be embedded on hospitals' websites using PayerAnalytics technology.

MRI of the Brain (with and without contrast)

Charge Type Price
Gross Charge $2,500
Discounted Cash Price $1,200
Payer-Specific Negotiated Charges Payer A: $1,800
Payer B: $1,950
De-Identified Minimum Negotiated Charge $1,700
De-Identified Maximum Negotiated Charge $2,100

CT Scan of the Abdomen and Pelvis (with contrast)

Charge Type Price
Gross Charge $1,800
Discounted Cash Price $900
Payer-Specific Negotiated Charges Payer A: $1,400
Payer B: $1,500
De-Identified Minimum Negotiated Charge $1,300
De-Identified Maximum Negotiated Charge $1,600

Colonoscopy (screening)

Charge Type Price
Gross Charge $3,000
Discounted Cash Price $1,500
Payer-Specific Negotiated Charges Payer A: $2,200
Payer B: $2,400
De-Identified Minimum Negotiated Charge $2,000
De-Identified Maximum Negotiated Charge $2,600

Interested in learning how PayerAnalytics can support your organization's internal workflow for price transparency? Contact us to schedule a demo and discuss how our platform can help streamline operational activities.

Frequently Asked Questions (FAQ)

The federal Hospital Price Transparency rule requires hospitals to make their standard charge information publicly available. This includes payer-specific negotiated rates and other types of standard charges, published in both a Machine-Readable File (MRF) and a consumer-friendly display or price estimator for shoppable services. The overall goal is to provide more accessible information about the cost of care.

Hospitals are currently expected to:

  • Publish a CMS-aligned Machine-Readable File (MRF) of standard charges
  • Provide a consumer-friendly shoppable services display (or compliant price estimator)
  • Include a footer link to the hospital's price transparency page
  • Maintain a TXT file in the website's root folder for CMS automated retrieval

Under the CY 2026 OPPS/ASC Final Rule, beginning January 1, 2026, hospitals will be expected to include additional pricing-related elements for certain payer-specific negotiated charges, such as median allowed amounts, 10th and 90th percentile allowed amounts, and the count of allowed amounts used in these calculations. CMS has indicated that these elements will be subject to enforcement beginning in April 2026.

Organizations should review regulatory details with their internal compliance and legal teams to confirm how these requirements apply to their specific circumstances.

CMS may impose Civil Monetary Penalties (CMPs) for non-compliance with Hospital Price Transparency requirements. Penalties are generally calculated on a per-day basis and can reach significant annual amounts for larger hospitals. CMS may also publicly post the names of hospitals that are out of compliance, which can have reputational implications.

CMS policies and penalty structures can change over time, so hospitals should rely on the latest CMS materials and consult with their compliance and legal teams for current details.

Benchmarking negotiated rates using transparency data can help provider organizations:

  • Identify pricing variation across services and payers
  • Support internal rate and contract strategy discussions
  • Highlight potential opportunities for optimization
  • Gain better visibility into their position in the market

These insights can complement internal revenue cycle, managed care, and strategic planning activities.

PayerAnalytics provides an integrated, AI-powered solution that supports hospitals with the operational work associated with Hospital Price Transparency. The platform is designed to:

  • Ingest and normalize pricing and remittance data (including ERA/835 files)
  • Support calculation of allowed-amount values referenced in recent CMS rules
  • Structure datasets in alignment with CMS-published MRF templates
  • Power consumer-facing shoppable services experiences
  • Provide benchmarking and analytics using publicly available transparency data

The solution is intended to support internal workflows. PayerAnalytics does not provide legal or regulatory advice, and use of the platform does not guarantee compliance. Hospitals remain responsible for reviewing all disclosures with their compliance and legal teams.

You can contact our team to schedule a demo. We will walk you through the solution and discuss how it can support your organization's Hospital Price Transparency implementation efforts.

Disclaimer: This page is intended for informational purposes only and does not constitute legal or compliance advice. The content summarizes publicly available CMS materials and does not interpret regulatory requirements. PayerAnalytics does not provide legal or regulatory advice, and use of this platform does not guarantee compliance with federal price transparency requirements. All CMS regulatory interpretations should be reviewed with your compliance or legal team. Implementation approaches should be reviewed with compliance teams to ensure alignment with your organization's internal policies and governance. Users are responsible for ensuring the accuracy and completeness of their disclosures. This platform is not affiliated with or endorsed by CMS or any government agency. This document does not reflect final agency action.

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