Hospital Price Transparency Machine-readable File: Compliance Overview

The healthcare landscape in the United States is in the midst of a major change with the enforcement of new hospital price transparency regulations, specifically tied to the re-introduction of an enhanced machine-readable file (MRF) of your pricing information. Healthcare organizations, from the C-suite down, must prioritize and thoroughly understand these changes to avoid substantial monetary penalties. Here is your guide to navigating the intricacies of this recently evolved critical compliance requirements that go into effect July 1, 2024.

Understanding the Legislation

The hospital price transparency requirements were first put into effect in 2021, aiming to give consumers accurate and accessible pricing information for hospital services. Fast forward to the present, and the focus has sharpened on the development and maintenance of a machine-readable file and a comprehensive database of standardized cost information that is required of each hospital. This MRF must include details of the standard charges, discounted prices, and payer-negotiated rates, offering transparency on an unprecedented level.
The latest addition to this legislation is an enhanced directive from the Centers for Medicare & Medicaid Services (CMS), which has issued new guidelines as of 2024, further standardizing the MRF format to ensure healthcare consumers can easily access and comprehend the data. These updates are more than an administrative adjustment—they represent much deeper and faster auditing, higher stakes and foresee severe penalties for noncompliance.

Legislation summary

All hospitals are required by U.S. federal regulation to provide a comprehensive, standardized machine-readable file (MRF) of clear pricing information online about the items and services they provide and to display shoppable services in a consumer-friendly format. Since adding more CMS standardization of the MRF format guidelines at the start of 2024, enforcement of these new guidelines will begin July 1, 2024. CMS may enforce civil monetary penalties for noncompliance. 

Additions made in 2024 since original legislation in 2021

  • All hospitals must update or overhaul existing MRF.

  • All hospital MRFs must now comply with a CMS template.

  • MRFs must meet new data and technical requirements.

  • CMS is updating the monitoring and enforcement process to increase government oversight of hospital price transparency compliance.

The Compliance Checklist

Fulfilling the requirements isn't simply about creating a file and calling it a day. CMS's expectations are rigorous and specific, down to the file-naming conventions and the implementation of internet-based price estimator tools. Here's a detailed checklist to ensure your facility is compliant.

1. Establish your digital MRF

Your hospital's MRF should be a comprehensive store of the prices of every service and item your hospital offers. The file should include gross charges, discounted cash prices, payer-specific negotiated costs, and de-identified maximum and minimum negotiated charges. Accuracy and completeness in representation are paramount, and a regular update schedule should be established. Rivet can help you stay up-to-date with your MRF in seconds so that your schedule doesn’t have to be quite so stringent. 

2. Create online accessibility and linking

Your homepage needs to include a footer that directly links to the MRF webpage. This is not just a regulatory text; it's a signifier of your hospital's commitment to accessible healthcare information. Further, the inclusion of a .txt file at the root of the MRF directory is vital, providing clear instructions and organization for CMS and consumers alike.

3. Attest to compliance accuracy

Include a clear and unequivocal statement on your MRF confirming that all applicable charges according to 45 CFR part 180 have been included. This declaration of completeness and accuracy goes beyond mere compliance; it's a commitment to ethical, transparent business practice.

4. Name your file correctly

The naming convention for your MRF is not a trivial matter. It should be precise, including your facility's EIN, name, and the specific type of file (.json, .xml, .csv). Details matter when it comes to honoring regulations, and this small consideration could avoid significant issues.

5. Display shoppable services on your website

At least 300 services, or your institution's unique set, must be curated and displayed for patients to 'shop' in advance. These services should not only be categorically and descriptively accurate but must also include pricing that reflects cash discounts, negotiated cost for specific payers, and the range of hidden and maximum negotiated rates. This is consumer education and empowerment translated into action.

For consumers, who may be navigating the sands of a complex healthcare system, the use of an online, internet-based price estimator tool is mandatory. This pricing tool should be user-friendly and robust, providing an accurate estimation of what services may cost. It's an investment in the consumer's trust and comfort that cannot be overlooked. Rivet’s self-serve estimator tool allows you to offer a simple, three step process for potential patients to price your shoppable services: 1) Select a service, 2) Add patient information (i.e., insurance info or self-pay), and 3) Get estimate. With Rivet’s easy-to-use estimates on your website, we can keep you compliant, you can stay compliant, and your patients can gain the transparency they’re looking for. 

6. Send additional CMS requirements as needed

In addition to the regular checklist, be prepared for CMS to ask for more. Certification of data accuracy, related documentation, and an acknowledgment of any compliance notices are likely requests. Be proactive in understanding and addressing these potential demands as part of your initial compliance efforts.

Noncompliance Auditing From 2022 to Now

Before the new CMS MRF template, CMS needed to manually audit compliance for individual hospitals. This meant that noncompliance could be negotiated, and in many cases, delayed. The new template forces standardization across the board for all hospitals, making it easy to streamline noncompliance audits. The newest 2024 legislation states that CMS now has a new, automated system for auditing for noncompliance that will make harsher penalties more difficult to avoid. Hospitals should expect penalization after the newest additional legislation goes into effect July 1. 

The Penalties of Noncompliance

The consequences of failing to comply with these regulations are not to be trifled with. CMS guidelines stipulate a phased penalty system, starting with warning notices that grant a limited time for correction. If ignored, fines begin and can escalate to significant daily rates, dependent on bed count and days of noncompliance. Organizational impact assessments will involve both financial and reputational costs, with penalties exceeding a million dollars in extreme cases.

Average complete CMS case cycle is 195 – 220 days. Here is how the timeline is broken down.

1. Warning notice with instructions to correct deficiencies within 90 days
              a. Over the past two years, CMS has issued approximately 1,000 warning notices to hospitals.

2. Corrective action plan (CAP) request (45-day deadline for hospitals to submit a CAP)
              a. Hospitals must submit a proposed completion date for CMS approval (~30-90 days)

3. Civil monetary penalty (CMP) will then be enforced
             a. All those that have received CMPs are posted and made publicly available on the CMS website

             b. For a full calendar year of noncompliance, the minimum total penalty amount would be $109,500 per hospital and                           maximum total penalty amount would be $2,007,500.
             c. Rate of CMP is as follows:

Screenshot 2024-04-12 at 7.43.11 AM

Examples of Noncompliance

Examples of non-compliance are not just theoretical. Hospitals across the country have faced penalties, as outlined in the breakdown. The costs associated with civil monetary penalties underscore the urgency and precision required in meeting the expectations of this legislation.

Screenshot 2024-04-12 at 7.46.48 AM


Hospital price transparency requirements are expanding in scope and importance, with CMS issuing stricter guidelines to ensure accessibility and accuracy of cost information. Compliance involves more than simply checking off a list; it requires a commitment to transparency and patient empowerment that has significant consequences for non-compliant facilities. By staying informed and proactive, hospitals can avoid the penalties associated with non-compliance and build trust with their patients and communities.  So, it is crucial for hospitals to prioritize compliance with these regulations in order to continue providing quality and transparent healthcare to patients. By implementing the necessary measures and regularly updating their MRF, hospitals can not only meet CMS expectations, but also foster a stronger relationship with patients built on trust and transparency.  Remember, compliance is an ongoing process that requires diligence and attention to detail. Stay informed and stay compliant!

Seeking Professional Help

Navigating any new legislation can be daunting. For many, the process of achieving and maintaining compliance with the hospital price transparency MRF requirements may involve the expertise of health law professionals, compliance officers, and healthcare consultants. These individuals and teams are equipped to interpret the regulations, assess your current state of readiness for compliance, and guide you through the corrective steps necessary to avoid the costly repercussions of non-compliance.

Whether your institution is a large urban hospital or a smaller rural facility, preparation and ongoing vigilance are key to not only meeting the regulatory standards but also to maintaining consumer trust and positioning your organization as a leader in the evolving landscape of healthcare transparency.

Rivet offers free compliance auditing so that you can start where you’re at instead of at the drawing board. See more on our MRF website for more information.

In conclusion, hospital price transparency compliance is no small feat, and it requires an ongoing commitment to accuracy and accessibility in healthcare pricing information. With Rivet’s software solution, you can get compliant and stay compliant. You can create and keep your MRF up-to-date in no time, as well as offer self-serve estimates on your website to allow for transparency without the hassle. Let's work together towards creating transparency.

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