Price Transparency Compliance: Avoiding Common Pitfalls

Introduction

Healthcare price transparency regulations are complex, and non-compliance can result in significant penalties. Many organizations struggle with implementation, not because they're trying to avoid transparency, but because the requirements are detailed and easy to misunderstand.

This guide identifies the most common compliance pitfalls and provides practical guidance on how to avoid them, based on CMS enforcement actions and industry best practices.

Understanding the Requirements

Hospital Price Transparency (45 CFR Part 180)

Hospitals must:

• Publish a machine-readable file with all standard charges
• Provide a consumer-friendly display of shoppable services
• Use the CMS template format (as of July 1, 2024)
• Update files at least monthly

Transparency in Coverage (85 FR 72158)

Health plans and issuers must:

• Publish in-network negotiated rates files
• Publish out-of-network allowed amounts files
• Make files publicly accessible without restrictions
• Update files monthly

Common Pitfall #1: Incomplete Data

The Problem

Many organizations publish files that are missing required data elements or only include partial information.

Examples of Incomplete Data

• Missing standard charge types (only showing gross charges, not negotiated rates)
• Incomplete provider information
• Missing service codes or descriptions
• Incomplete date information
• Missing required attestation statements

How to Avoid It

1. Use the CMS Template: The CMS template includes all required fields. Don't create your own format.
2. Complete Data Audit: Before publishing, verify that you have: