CMS requires a machine-readable format — JSON or CSV that software can parse automatically. If your file doesn't parse cleanly, CMS treats the data as not published. Format errors trigger the same $5,500/day fine as missing data.
A compliant MRF groups data by payer, then by plan, then by item or service. Each entry includes: billing code, description, gross charge, discounted cash price, and negotiated rate. The JSON must be valid, complete, and consistent.
At minimum: item name, billing code (CPT/HCPCS), gross charge, discounted cash price, minimum and maximum negotiated rates, and per-payer negotiated rates with clear plan identifiers.
The most frequent issues: malformed JSON (missing brackets, trailing commas), inconsistent code formats, duplicate entries, empty price fields, and files that exceed CMS size limits or time out.
Before publishing, validate the JSON with a parser, verify all fields are populated, and confirm an automated crawler (not just a browser) can download it.
A compliance validator parses your file exactly the way CMS's systems do — catching format errors, missing fields, and structural problems before they become fines.
Not sure your JSON parses cleanly? Free MRF risk check catches format errors too.
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