Hospital MRF Compliance Checklist

Reviewed November 3, 2026. This operational checklist supports a review; it does not certify compliance or replace the regulation. It has been revised for the 2026 hospital requirements rather than the separate payer MRF rules.

CMS’s March 2026 hospital guidance and hospital FAQs are the primary sources. The 2026 changes took effect January 1, 2026, with enforcement of the new allowed-amount, attestation, and NPI requirements beginning April 1, 2026.

Publication and discovery

1. Public access: Test the MRF from outside your organization. It must be available without payment, an account, or submission of personally identifiable information.
2. Discovery: Check the homepage footer link and the root-level cms-hpt.txt file required to help users and automated systems locate the MRF. The root-level text file is not the MRF itself.
3. Naming and freshness: Use the CMS naming guidance, confirm the file date, and verify that standard-charge information has been updated at least annually.

Use the naming wizard, text-file generator, and validator linked from CMS Hospital Price Transparency resources. Do not apply a payer schema version to a hospital file.

Format and charge information

4. Applicable template: Validate against the current CMS hospital CSV or JSON template and data dictionary.
5. Required charge types: Reconcile gross charges, discounted cash prices, payer-specific negotiated charges, and de-identified minimum and maximum negotiated charges with the hospital’s underlying records.
6. Service context: Check descriptions, applicable billing codes, payer and plan names, settings, and other required fields against the data dictionary. Apply conditional fields where required, including drug units and modifiers.
7. Non-dollar arrangements: Where a payer-specific negotiated charge is based on a percentage or algorithm, confirm that the required information to derive a dollar amount is included. Do not replace a known negotiated dollar amount with an estimate.

Current allowed-amount requirements

8. Four allowed-amount elements: For applicable percentage- or algorithm-based negotiated charges, encode the median, 10th percentile, 90th percentile, and count of allowed amounts. The former estimated allowed amount was replaced in 2026.
9. Calculation evidence: Use EDI 835 remittance data or an equivalent source and the required contiguous lookback period of no less than 12 months and no more than 15 months. Follow the CMS FAQ instructions for limited or absent claims, and retain the calculation method and source period.

These hospital fields are not the same as the out-of-network allowed-amount disclosures in payer files. See our hospital MRF versus payer MRF guide for the distinction.

Accountability and identifiers

10. Attestation: Include the required attestation and the name of the CEO, president, or designated senior official. Confirm the statement covers completeness, known dollar amounts, and information needed to derive non-dollar amounts.
11. Organizational NPIs: Include active Type 2 NPIs associated with primary taxonomy codes beginning with 28 or 27, as specified by CMS.
12. Evidence and ownership: Retain the published file, validation results, source records, review date, and assigned remediation owners. Reconcile the data itself, not just the presence of fields.

A valid file is not the whole obligation

CMS states that its validator can identify technical issues, but passing technical checks does not establish compliance with every requirement. The separate consumer-friendly shoppable-services obligation also needs review: generally at least 300 services, or as many as the hospital provides if fewer, with a compliant price estimator as an alternative.

For historical context, see the 2025 hospital guide with its 2026 update. For support with your review, explore SumHealth’s compliance services. Do not treat this checklist or a vendor tool as a CMS certification.