The History of Hospital Price Transparency

What’s New in Hospital Price Transparency and How Did We Get Here?

The CY24 OPPS Final Rule contains additional information and requirements regarding hospital price transparency. The changes build on transparency requirements previously established in past rules and other regulations.


In 2010 the ACA responded to calls for price transparency.

In 2014 the FY15 IPPS proposed rule called for hospitals to make pricing available to the public by posting the CDM information or providing a way for the public to access it.

In 2018 the FY19 final rule required hospitals to make a list available of their standard charges with a machine readable format and to update it annually.

In 2019 President Trump signed an executive order calling for additional transparency policies and guidelines.

Also in 2019, the CY20 OPPS Final Rule called for updates to pricing and payment disclosures included in a machine readable file as well as a consumer shoppable posting.

The FY19 IPPS Final Rule initiated requirements in order for hospitals to comply with language in the Affordable Care Act. The rule required hospitals to “make available a list of their current standard charges via the Internet in a machine readable format and to update this information at least annually, or more often as appropriate. This could be in the form of the chargemaster itself or another form of the hospital’s choice, as long as the information is in machine readable format.”

In 2020 the FY21 Final Rule required for Medicare cost reports to include the median health plan-specific negotiated rates for inpatient services by MS-DRG.

CY20 OPPS Final Rule on Transparency introduced, as a continuation of the FY19 IPPS Final Rule, the CY20 OPPS Final Rule on Transparency, additional clarification and requirements for hospitals. These requirements became effective on January 1, 2021 and included the following key elements. This included a definition of “hospital” that requires nearly all hospitals to comply with the rule, definitions for five types of “standard charges” to be disclosed by hospitals (gross charge, discounted cash price, payer specific negotiated charge, and the deidentified minimum and maximum negotiated charge), a definition of hospital “items and services” that include all items and services (including individual items, services, service packages, and employed professional fees) provided by the hospital to a patient in connection with an inpatient admission or an outpatient department visit, requirements for making public a machine-readable file that contains all definitions of standard charges for all items and services and service packages provided by the hospital, and requirements for making certain standard charges public for select hospitalprovided items and services that are “shoppable” and that are displayed in a consumer-friendly manner – either through a file or a web-based patient estimation tool; vi. Non-compliance monitoring, actions, civil monetary penalties, and appeal process.

The CY22 OPPS Final Rule included key updates for hospitals including a significant increasing of the monetary penalties for non-compliance and the prohibition of barriers to automatic download of the machine-readable file on a hospital’s website.

To learn more about changes in the CY24 rule, see our white paper here!

Have questions about your hospital’s transparency files? We’d love to help!

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