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Hospital MRF Compliance Checklist: 12 Things to Verify Before Your Next CMS Audit
A practical compliance checklist for hospital CFOs and compliance officers covering the most common MRF deficiencies cited by CMS — and how to verify each one before auditors do.
SumHealth Compliance Team November 3, 2025 · 2 min read
Use this checklist to assess your hospital’s machine-readable file compliance posture before a CMS audit cycle. Each item corresponds to a deficiency category that CMS has cited in enforcement actions.
File Publication & Accessibility
- MRF is published at your root domain (e.g.,
hospital.org/pricing/) — not a subdomain - MRF URL follows CMS naming convention:
<EIN>_<hospital-name>_standardcharges.[json|csv] - File has been updated within the last 12 months
- File is accessible without a paywall, login, or CAPTCHA
- File loads successfully from a public network (test from outside your firewall)
Schema & Format
- MRF is published in CMS schema version 2.0.0 (not an earlier version)
- All required fields are present:
hospital_name,last_updated_on,version,hospital_location - Standard charges include all five required charge types: gross, discounted cash, payer-specific negotiated, de-identified minimum, de-identified maximum
Provider Identifiers
- Hospital NPI matches the active record in NPPES
- EIN matches the organization’s IRS registration
- All billing NPI references for provider-specific rates resolve to active NPPES records
Rate Record Completeness
- Payer-specific negotiated rates are present for all active payer contracts
- Each rate record includes the associated plan name and billing code
- De-identified minimum and maximum negotiated rates are distinct from payer-specific rates
SumHealth’s Compliance Monitor automates all 12 of these checks continuously, alerting your team before CMS does.
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