A Response to the CY27 OPPS Proposed Rule Request for Information Regarding Strengthening the Standardization and Comparability of Hospital Price Transparency (HPT) Data

CMS recently issued a Request for Information (RFI) seeking stakeholder feedback on opportunities to improve the standardization, comparability, and usability of Hospital Price Transparency (HPT) data. Cleverley + Associates has prepared a detailed response based on our experience modeling thousands of hospital-payer contracts and producing Machine-Readable Files (MRFs) for hundreds of hospitals. Our full response can be found here: CY27 OPPS Proposed Rule Response PDF

Our comments focus on five key themes:

1. Build Upon Existing Transparency Tools Rather Than Creating New Data Elements
   • Enhance algorithm descriptions and allowed amount reporting rather than continually expanding the MRF schema with new reporting fields.

2. Complexity Should Be Communicated, Not Encoded
   • Focus on standardized terminology, reimbursement anchor points, and reimbursement outcomes rather than attempting to encode every contractual provision into discrete data elements.

3. Standardize Algorithm Descriptions Through a CMS Algorithm Component Data Dictionary
   • Establish common terminology and formatting conventions so reimbursement methodologies can be communicated consistently while remaining machine-readable.

4. Allowed Amount Reporting Is the Most Meaningful Transparency Data
   • Improve comparability through standardized allowed amount reporting using MS-DRG and primary APC claim groupers.

5. Consumer Transparency Is Best Delivered Through Technology, Not Larger Files
   • Continue leveraging Price Estimator Tools (PETs) and payer comparison tools that translate hospital and payer transparency data into personalized cost estimates for consumers.

We encourage hospitals and health systems to provide comments directly to CMS. The agency is specifically seeking stakeholder feedback on future Hospital Price Transparency requirements, and provider input remains critical to shaping policy outcomes.

Electronically (Preferred)
Submit comments through the Federal eRulemaking Portal:
https://www.regulations.gov/docket/CMS-2026-2344
Follow the “Comment” instructions

By Regular Mail
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1850-P
P.O. Box 8010
Baltimore, MD 21244-8010

By Express or Overnight Mail
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-1850-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

As always, please feel free to reach out if you would like to discuss the RFI, its potential implications for your organization, or any hospital price transparency issue.”