Changes to Federal Transparency Posting Requirements Begin January 1, 2024

December 19, 2023

The recently finalized Medicare Outpatient Prospective Payment System (OPPS) and ambulatory surgical center rule includes significant changes to how hospitals must make available machine-readable files of negotiated payments with carriers for specific services on their websites. These changes apply to all hospitals, not just ones paid under the Medicare OPPS payment methodology. Some of the new requirements occur as early as January 1, 2024, though WSHA in its comments requested a longer period for hospitals to make any needed changes. The American Hospital Association provided details of the specific changes in its recent Regulatory Advisory. The following summary is to help hospitals prepare for the changes.

Effective January 1, 2024. Hospitals are required to comply with new requirements to ensure the machine-readable files (MRF) are accessible on their website. These include ensuring a link to the machine-readable file in the footer of their public website labeled “Price Transparency.” Hospitals must also include a txt file in their website’s root folder containing the MRF and source page URLs. Hospitals must also make a good faith effort to ensure accuracy and completeness of posted information.

Effective July 1, 2024. Hospitals will be required to post an affirmation in each MRF that the hospital has to the best of its knowledge provided accurate and complete information. Hospitals will also need to adopt a new standardized format template for display of information in machine readable files and include most of the newly required data elements, including payment methodology and estimated payment amount. Information on the new templates is at GitHub – CMSgov/hospital-price-transparency.  Also, hospital staff can register for a CMS webinar on January 17 from 11–12:30 pm to

  • Review the new requirements
  • Present examples of how to encode MRF standard charge information in the CMS template layout
  • Demonstrate the GitHub repository

One welcome change is that the rule clarifies hospitals are not required to post separately contracted rates for all of a carrier’s different products when it is paid a single rate by the carrier.

Effective January 1, 2025. Hospital will be required to include the remainder of the new elements, including those related to drugs and payment effect of billing modifiers.

As part of enhanced compliance monitoring and enforcement, CMS will require hospitals to acknowledge receipt of warning notices and may ask an authorized officer of the hospital to sign an affirmation of completeness and accuracy if the hospital is undergoing a warning or corrective action process. The rule also allows CMS to publicize the names of hospitals undergoing compliance action. (Andrew Busz,


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