CMS Penalty Exposure Calculator

The exact math behind a price-transparency fine: $300/day, escalating to $5,500/day after the second notice, capped at ~$2.08M per year.

Failed CMS elements (from an audit): 2

1 (minor)35 (severe)

Days until fixed: 90

15 days180365 days

Estimated exposure

$669,000

Risk level: MEDIUM · 2 failed element(s) · 90 days at risk

Assumes CMS's corrective-action window (~30 days) before escalation, per 45 CFR §180.30. Actual fines vary by enforcement history.

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How the CMS fine schedule works

Under 45 CFR §180.30, CMS can fine a hospital $300 per day for a missing or non-compliant machine-readable file. After a second notice, the penalty rises to $5,500 per day. The annual cap for 2024 was approximately $2,077,733, adjusted for inflation each year.

The most common triggers: no MRF published, a file that fails the required JSON schema, missing payer-specific negotiated rates, absent cash prices, or no 70-item shoppable services display.

The good news: the fix is mechanical. A full audit identifies exactly which elements fail, and remediation typically takes about three weeks. See how we run it →

Not sure if you're compliant?

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