CMS Price Transparency Guidelines

Overview

On January 1, 2021, CMS implemented the Hospital Price Transparency final rule (45 CFR 180.50) requiring hospitals to make standard charges publicly available in machine-readable formats. Non-compliance can result in fines ranging from $300 to $5,500 per day.

This guide summarizes the key requirements. Always refer to official CMS guidance for authoritative information.

Who Must Comply?

The rule applies to:

• All hospitals operating in the United States
• Licensed or certified as a hospital under state law
• Hospitals with a provider agreement under Medicare

Exemptions: Certain specialty hospitals and psychiatric facilities may have modified requirements. Consult CMS guidance for your specific facility type.

Core Requirements

Required Data Elements

The machine-readable file must include these data elements for each item/service:

File Format Requirements

JSON Format (Recommended)

CMS provides a JSON schema that files should follow. Key requirements:

{
  "hospital_name": "Example Hospital",
  "last_updated_on": "2025-01-01",
  "version": "1.0.0",
  "hospital_location": ["San Francisco, CA"],
  "license_information": {
    "license_number": "12345",
    "state": "CA"
  },
  "standard_charge_information": [
    {
      "description": "Emergency Department Visit - Level 3",
      "drug_unit_of_measurement": null,
      "code_information": [
        {
          "code": "99283",
          "type": "CPT"
        }
      ],
      "standard_charges": [
        {
          "gross_charge": 750.00,
          "discounted_cash_price": 600.00,
          "payer_name": "Blue Cross Blue Shield",
          "plan_name": "PPO Plan",
          "contracting_method": "fee schedule",
          "standard_charge_dollar": 575.00
        }
      ]
    }
  ]
}

File Accessibility

• File must be publicly accessible without authentication
• No click-through agreements or barriers
• Should support direct download
• Must be linked from hospital's primary website
• URL should be stable and not change frequently

Common Violations

Based on CMS enforcement actions, these are the most common compliance issues:

Enforcement & Penalties

Enforcement Process

1. Warning Notice: CMS typically issues a warning and provides 90 days to come into compliance.
2. Request for Corrective Action Plan: Hospital must submit a plan to address violations.
3. Civil Monetary Penalty: If non-compliant after deadline, CMS may assess daily penalties retroactive to the warning date.
4. Public Disclosure: CMS publishes enforcement actions on their website, creating reputational risk.

CMS Enforcement Actions

CMS maintains a public list of hospitals under investigation and those that have received penalties:

As of October 2025, hundreds of hospitals have been cited for violations, with dozens receiving civil monetary penalties.

Best Practices