CMS assesses civil monetary penalties of $5,500 per day per violation under 45 CFR 180.50. A 'violation' is any failure to meet a specific requirement — meaning multiple violations can accrue simultaneously across different file deficiencies.
CMS has issued 1,000+ penalty actions since enforcement began, covering hospitals of all sizes. Early enforcement focused on the most egregious failures — missing files entirely — but later waves target partial compliance: missing payers, absent cash prices, unreachable files.
The agency's approach has hardened: automated crawlers continuously check files; warning letters precede fines; and once a fine starts, it accrues daily until the file is verified fixed. Hospitals that respond fast cap their exposure; those that delay accumulate six-figure penalties.
A hospital cited for three violations (missing payer rates, missing cash prices, bot-blocked file) accrues $16,500 per day. Two weeks = $231,000. A month = $495,000.
The facilities that never get cited run proactive compliance: complete files, verified crawler access, quarterly re-checks, and fast remediation when contracts change.
The only way to know your exposure is to audit the file. A free risk check tells you exactly what CMS would cite today.
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