Hospital Price Transparency: 2025 Guide and 2026 Update
Understand the 2025 hospital price transparency baseline and the 2026 changes to allowed amounts, attestation, and NPIs, with CMS sources and a review checklist.
Originally published August 13, 2025. Reviewed and corrected November 3, 2026. This page preserves the 2025 context and identifies the subsequent 2026 changes separately. For an operational review today, use the current hospital MRF compliance checklist.
Hospital Price Transparency and Transparency in Coverage are different regulatory programs. This guide concerns hospital standard charges, not the payer machine-readable file obligations.
The hospital publication baseline
CMS requires covered hospitals to publish standard-charge information in two ways:
- A comprehensive machine-readable file in the applicable CMS CSV or JSON template, containing gross charges, discounted cash prices, payer-specific negotiated charges, and de-identified minimum and maximum negotiated charges.
- A consumer-friendly display of at least 300 shoppable services, or as many as the hospital provides if fewer. A price estimator that meets the regulatory conditions can serve as an alternative.
The display and estimator are not interchangeable without checking the requirements. See CMS’s hospital guidance for the distinction.
What changed during 2025?
The January 2025 implementation stage added requirements including drug-unit information, modifiers where applicable, and an estimated allowed amount for applicable percentage- or algorithm-based negotiated charges. This estimated allowed amount was a hospital disclosure; it was not a general requirement to estimate out-of-network reimbursement.
The CMS hospital resources provide the templates, data dictionaries, and implementation materials. Our hospital data-element timeline supplies additional historical context.
Do not carry the 2025 estimated-allowed-amount instructions forward into a current file without applying the 2026 changes.
Current update: 2026 requirements
The CMS hospital FAQs distinguish the January 1, 2026 effective date from the April 1, 2026 start of enforcement for the new allowed-amount, attestation, and NPI requirements.
Allowed amounts replaced the estimate
For applicable percentage- or algorithm-based payer-specific negotiated charges, hospitals must encode median, 10th percentile, and 90th percentile allowed amounts, plus the count used in the calculations.
Calculations use EDI 835 electronic remittance advice or an equivalent source and a contiguous lookback period of no less than 12 months and no more than 15 months. Consult the CMS FAQs for incomplete claims histories and cases with no claims. Do not invent a value to fill a missing observation.
Attestation replaced the affirmation
Hospitals must include the updated attestation and name the CEO, president, or designated senior official. The statement addresses completeness and accuracy, known dollar amounts, and the information needed to derive non-dollar negotiated charges.
Organizational NPIs became required
Hospitals must report the active Type 2 NPIs associated with primary taxonomy codes beginning with 28 or 27 as specified by CMS. These are organizational identifiers, not a requirement to list every individual clinician’s NPI.
Review publication and data quality separately
Confirm that visitors can find and retrieve the file, that the homepage footer and root-level text file support discovery, and that the information has been updated at least annually. Then reconcile charge information with the underlying records and validate the applicable template.
CMS warns that meeting technical specifications for form and manner does not establish compliance with all requirements. A valid schema does not prove that every applicable negotiated charge has been included.
Enforcement is not a single fixed penalty
CMS may review hospitals, request corrective action, and impose civil monetary penalties. Follow the requirements and deadlines in the actual CMS notice; do not assume every notice has the same response timetable.
The March 2026 guidance also describes a conditional 35% penalty reduction when a hospital waives its right to an administrative law judge hearing. Whether to waive appeal rights is a legal decision, not a checklist step.
Plan your next review
Use the hospital MRF compliance checklist to assign review owners and document findings. SumHealth’s compliance services can support the review process. This article is educational guidance, not legal advice or a guarantee of compliance.
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