The Hospital Price Transparency Compliance Checklist: 15 Points Before CMS Audits You

1-5: The File Basics

1. MRF exists and is publicly accessible. 2. No login or paywall. 3. Automated crawlers can download it (no bot-blocking). 4. JSON or CSV format — not PDF/HTML. 5. File size within CMS limits and loads reliably.

6-10: The Data

6. Gross charges on every item. 7. Discounted cash price on every item. 8. Payer-specific negotiated rates for every contracted plan. 9. All 70 shoppable services present with correct codes. 10. Minimum and maximum negotiated rates included.

11-15: Maintenance & Proof

11. File updated after every payer contract change. 12. Versioning or timestamp visible. 13. Internal owner assigned for file maintenance. 14. Quarterly re-validation scheduled. 15. Previous audit findings all remediated.

How to Use This Checklist

Run through the 15 points quarterly. A 'no' on any point is a potential violation. Most hospitals discover 3-6 gaps on first review — which is exactly why CMS finds them non-compliant.

The Cost of a Missed Point

Each failed point is a potential $5,500/day violation. Three gaps, one month = $495,000. The checklist exists to find gaps before CMS does.

Automated Compliance

A compliance audit runs every check on this list against your actual file — in minutes, not weeks, with a documented report for your compliance file.

Run the checklist against your file automatically — free risk check.

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