CMS v3.0 Specification

Evolution of Required MRF Data Elements Across Final Rules

A chronological guide to how hospital price transparency data requirements have expanded from 2021 through the 2026 enforcement rules. Explore the definitions and regulatory history of each required element.

Reviewed November 3, 2026. The 2026 allowed-amount fields apply to the relevant percentage- or algorithm-based negotiated charges. Use a contiguous lookback period of 12 to 15 months and follow CMS instructions for limited or absent claims. The comparison is an educational summary, not a substitute for the current data dictionary.

Sources: CMS hospital guidance and CMS hospital FAQs. For an operational review, use the hospital MRF compliance checklist.

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Hospital MRF data elements across five final-rule periods. Open a data element to read its definition and why it matters.
Data Element	CY 2020Eff. Jan 2021	CY 2022Eff. Jan 2022	CY 2024Eff. Jul 2024	CY 2024/25Eff. Jan 2025	CY 2026Enforced Apr 2026
HOSPITAL IDENTIFICATION
Hospital Name The legal or commonly used name of the hospital reporting its prices. Why it matters: Lets patients and researchers identify exactly which hospital the pricing data belongs to, especially in multi-hospital health systems.	Introduced	check	check	check	check
Location Name The name of a specific campus, clinic, or satellite location within a hospital system. Why it matters: Large hospitals often have multiple locations with different prices. This tells you which building or campus the charges apply to.	Introduced	check	check	check	check
Hospital Address The street address of the hospital location, including city, state, and ZIP code. Why it matters: Helps patients find pricing for the facility nearest to them rather than a location across the state.	Introduced	check	check	check	check
License Number (State) The state-issued license number that officially authorizes the hospital to operate, along with which state issued it. Why it matters: Provides a unique government-verified ID for each hospital, preventing confusion when multiple hospitals share similar names.	Introduced	check	check	check	check
Organizational NPI A Type 2 National Provider Identifier — a 10-digit number assigned to the hospital as an organization (not to individual doctors). Why it matters: NPIs are the standard way to look up a healthcare organization in federal databases. Adding this makes it easy to cross-reference hospital pricing with insurance claims and other public data.	—	—	—	—	Introduced
Attester Name The first and last name of the hospital CEO, president, or senior official who personally certifies that the pricing data is accurate and complete. Why it matters: Puts a real person's name behind the data, creating personal accountability. Before this, hospitals could submit inaccurate data with no individual taking responsibility.	—	—	—	—	Introduced
Affirmation Statement The affirmation used before the 2026 attestation requirements. Why it matters: Historical field replaced by the expanded attestation in 2026.	—	—	Introduced	check	Removed
Attestation Statement The 2026 statement addresses completeness, accuracy, known negotiated dollar amounts, and information needed to derive non-dollar amounts. Why it matters: Requires an explicit statement and named senior official under the current requirements.	—	—	—	—	Introduced
ITEM / SERVICE DATA
Service Description A plain-text description of the medical service or item, such as "MRI of the brain without contrast" or "Acetaminophen 500mg tablet." Why it matters: Billing codes are cryptic. This human-readable description helps patients and researchers actually understand what they are being charged for.	—	—	Introduced	check	check
Billing Code The billing code (like a CPT, HCPCS, or DRG code) that identifies a specific medical service or procedure. Why it matters: Billing codes are the universal language of healthcare pricing. Without them, you can't compare the same service across different hospitals.	Introduced	check	check	check	check
Billing Code Type The coding system the billing code comes from — for example, CPT (procedures), NDC (drugs), DRG (hospital stays), or HCPCS (supplies and equipment). Why it matters: A code like "99213" only makes sense if you know it's a CPT code. This field prevents misinterpretation and enables proper apple-to-apple price comparisons.	Introduced	check	check	check	check
Care Setting Whether the service is provided in an inpatient setting (patient is admitted overnight) or an outpatient setting (patient goes home the same day). Why it matters: The exact same procedure can cost dramatically different amounts depending on whether it’s done inpatient vs. outpatient. This distinction is essential for accurate price comparison.	—	—	Introduced	check	check
Modifiers Additional two-character codes appended to a billing code that describe special circumstances — such as which side of the body, whether it's a repeat service, or if multiple procedures were performed. Why it matters: Modifiers change the price. A knee surgery billed with modifier "-50" (bilateral) costs more than one side alone. Without this, prices look misleading.	—	—	—	Introduced	check
Drug Unit of Measurement The quantity of drug per unit of billing — for example, "1" meaning one tablet, one mL, or one vial. Why it matters: A drug priced at $50 means nothing without knowing if that's per pill, per mL, or per vial. This makes drug pricing actually comparable.	—	—	—	Introduced	check
Drug Type of Measurement The unit type for drug billing — such as milligrams (mg), milliliters (mL), grams (g), or international units (IU). Why it matters: Works with Drug Unit of Measurement to eliminate ambiguity. "$10 per 500mg" is very different from "$10 per 5mL."	—	—	—	Introduced	check
STANDARD CHARGES
Gross Charge The hospital's full list price (also called "chargemaster" price) before any discounts, insurance adjustments, or negotiations. Why it matters: Think of this as the sticker price. Almost nobody pays it, but it's the starting point from which all discounts and negotiations begin.	Introduced	check	check	check	check
Discounted Cash Price The price a hospital charges patients who pay out of pocket without using insurance, typically offered at a discount from the gross charge. Why it matters: This is the price that matters most to uninsured patients or those choosing to self-pay. It’s usually much lower than the gross charge.	Introduced	check	check	check	check
Negotiated Dollar Amount The specific dollar amount a particular insurance company has agreed to pay the hospital for this service, as negotiated in their contract. Why it matters: This is the most revealing number — it shows what your insurance company actually pays, which varies enormously between insurers for the same service at the same hospital.	Introduced	check	check	check	check
Negotiated Percentage When the insurance contract is based on a percentage of another rate (like Medicare), this shows that percentage rather than a fixed dollar amount. Why it matters: Many contracts say "pay 150% of Medicare rates" instead of a flat dollar. This field captures that type of deal so the actual payment can be calculated.	—	—	Introduced	check	check
Negotiated Algorithm A text description of how the price is calculated when it’s not a simple dollar amount or percentage — for example, "per diem rate of $2,500 for days 1–3, then $1,800 per day after." Why it matters: Many hospital payments involve complex formulas, not flat rates. This ensures those complex pricing arrangements are disclosed rather than hidden.	—	—	Introduced	check	check
Minimum Negotiated Rate The lowest negotiated price any insurance company pays for this service at this hospital. Why it matters: Gives patients and researchers a floor price — showing the best deal any insurer has negotiated. Useful for understanding the range of what's possible.	Introduced	check	check	check	check
Maximum Negotiated Rate The highest negotiated price any insurance company pays for this service at this hospital. Why it matters: Shows the ceiling price. The gap between min and max reveals how much negotiating power matters — sometimes the max is 5–10x the min for the same service.	Introduced	check	check	check	check
Pricing Methodology How the negotiated price is structured: case rate (flat per-visit), per diem (daily rate), fee schedule (set price list), percent of total billed charges, or other. Why it matters: Knowing the pricing method is crucial for comparison. A $5,000 "case rate" for a surgery is very different from a $2,000 "per diem" rate that could span many days.	—	—	Introduced	check	check
Payer Name The name of the insurance company or third-party payer, such as "Blue Cross Blue Shield" or "Aetna." Why it matters: Lets patients look up exactly what their insurance company has agreed to pay at this hospital, rather than seeing generic averages.	—	—	Introduced	check	check
Plan Name The specific insurance plan within a payer, such as "Gold PPO" or "Silver HMO." A single insurer often offers many different plans. Why it matters: Even within the same insurer, prices can vary significantly between plans. Your "Gold" plan may have different negotiated rates than a "Bronze" plan.	—	—	Introduced	check	check
ALLOWED AMOUNTS
Estimated Allowed Amount The former field for applicable percentage- or algorithm-based payer-specific negotiated charges, not an out-of-network reimbursement estimate. Why it matters: Replaced in 2026 by median and percentile allowed amounts and their count.	—	—	—	Introduced	Removed
Median Allowed Amount The middle value of all allowed amounts the hospital actually received from a given payer over the past 12–15 months, calculated from real payment data (EDI 835 remittances). Why it matters: Replaces the old estimate with a real, data-backed number. The median is the "typical" payment — not skewed by unusually high or low outliers.	—	—	—	—	Introduced
10th Percentile Amount The value below which only 10% of actual payments fell. In other words, 90% of the time the payer paid more than this amount. Why it matters: Shows the low end of what the hospital actually gets paid. Helps identify cases where reimbursement is unusually low.	—	—	—	—	Introduced
90th Percentile Amount The value below which 90% of actual payments fell. Only 10% of payments exceeded this amount. Why it matters: Shows the high end of typical payments. Together with the 10th percentile and median, it reveals the full spread of what hospitals actually receive.	—	—	—	—	Introduced
Count of Remittances The number of individual payment remittances (transactions) the hospital used to calculate the median and percentile figures. Why it matters: A median based on 5 payments is much less reliable than one based on 500. This lets users judge how trustworthy the statistical figures are.	—	—	—	—	Introduced
NOTES & OPTIONAL
Additional Generic Notes A free-text field where the hospital can add context that applies broadly — like "prices do not include physician fees" or "updated quarterly." Why it matters: Healthcare pricing has endless nuances. This field catches important caveats that don't fit neatly into other structured fields.	—	—	Introduced	check	check
Additional Payer Notes Notes specific to a particular insurance payer's negotiated rates, available only in the "wide" CSV format where each payer gets its own column. Why it matters: Some payer contracts have unique conditions (e.g., "rate applies only to in-network referrals"). This captures payer-specific fine print.	—	—	Introduced	check	check
Financial Aid Policy An optional link or description of the hospital's financial assistance (charity care) program for patients who cannot afford to pay. Why it matters: Helps low-income patients discover they may qualify for free or reduced-cost care, which hospitals are required to offer but often don't advertise.	—	—	Introduced	check	check
General Contract Provisions Optional notes describing general provisions or terms in the hospital's contracts with payers that affect pricing. Why it matters: Provides transparency into the broader deal structure between hospitals and insurers, beyond just the dollar amounts.	—	—	Introduced	check	check
Billing Class An optional field indicating whether a service is classified as a "professional" charge (doctor's fee) or a "facility" charge (hospital fee). Why it matters: Patients often receive two separate bills for one visit — one from the doctor, one from the facility. This clarifies which charge is which.	—	—	Introduced	check	check

IntroducedElement first required in this rule

RemovedElement removed in this rule

Continues to be required

Not yet required

Note: CY 2026 changes are effective Jan 1, 2026 but CMS enforcement of new requirements begins Apr 1, 2026. The “Notes & Optional” group includes optional fields; appearance in this comparison does not mean every field is mandatory. For authoritative requirements and updates, seeCMS Hospital Price Transparency resources.