CMS HPT Tracker / price transparency audit

Explainer · 2 of 3

The CMS rules

Most hospitals must post two things: one big price file for researchers and programs, and an easy way for patients to look up common prices. They serve different people.

Who has to follow it

The rule follows hospital licensing

For this rule, a hospital is a place licensed as a hospital under state or local law, or approved as meeting those licensing standards.

That is wider than Medicare. Taking Medicare doesn’t put a facility in the rule or take it out. What counts is how the place is licensed or approved where it operates.

CMS treats some government and tribal hospitals as already compliant. The rule names three groups: federally owned hospitals (including Veterans Affairs and Department of Defense hospitals), hospitals run by an Indian Health Program, and state hospitals that only treat people held by prison authorities.

What hospitals post

Two things, for two audiences

Part 180 asks for a full price file, plus an easy patient view of a smaller set of services you can plan ahead for.

45 CFR 180.50

The full price file

A CSV or JSON file with every standard price for every item and service. That covers the list price, the cash price, each insurer’s negotiated price, and the lowest and highest negotiated prices.

45 CFR 180.60

The patient view of common services

A searchable list, or a qualifying price estimator, for services you can usually schedule ahead. It covers as many of 70 services picked by CMS as the hospital offers, plus more the hospital chooses, for at least 300 in total when available.

The patient view must let people search by description, billing code and insurer, unless the hospital uses an estimator. An estimator counts if it covers the required services, gives an estimate of what you would owe the hospital, is easy to find, and works without a fee or an account.

The price file is a different thing. It is meant to be downloaded and processed by a computer, and it can hold millions of rows. A hospital can have a good patient estimator and a broken price file, or the other way round.

Posting and access

The file has to be easy to reach in practice

A public web address isn’t enough if a person or a program has to get past barriers to reach the data.

No payment or account
The file must be free, with no sign-up and no password.
No personal details
Getting the file can’t depend on giving your name, email or other personal information.
Direct, automated access
Programs must be able to find and download the file from a link on a public website.
Searchable data
The file and the prices inside it must be searchable by a computer.
Standard file name
The name follows a CMS pattern: <ein>_<hospital-name>_standardcharges.csv or .json.
Signposts on the website
The site keeps a pointer file at /cms-hpt.txt and a footer link labeled “Price Transparency” that leads to the page hosting the price file.

The hospital also has to say which location the prices belong to. If sites under one license have different prices, each site must post its own.

Both the price file and the patient view must be updated at least once a year. The price file records its last update date. The patient view must show its update date clearly.

Timeline

The rule has gotten more specific

The main duty began in 2021. Later changes standardized how hospitals post and describe the data.

  1. Jan. 2021
    The posting rules took effectHospitals began posting a full price file and a patient view of common services.
  2. Jan. 2024
    Websites needed standard signpostsThe hospital’s website had to carry a /cms-hpt.txt pointer file and a footer link labeled “Price Transparency.”
  3. July 2024
    CMS templates became requiredPrice files had to follow a CMS template, its data rules and its data dictionary.
  4. Jan. 2025
    More detail became requiredThe template added the remaining fields for contract methods, allowed amounts, drug units and code modifiers.
  5. Jan. 2026
    The current rules took effectFiles now include a signed accuracy statement, a responsible senior official and organization ID numbers (NPIs). The single estimated allowed amount was replaced by 10th percentile, median and 90th percentile amounts plus a count.
  6. Apr. 2026
    CMS began enforcing the 2026 fieldsThe CMS technical guide gives April 1, 2026 as the date enforcement of the new template fields starts.

This timeline covers federal requirements only. A file made with an older template can still open fine, but a file that opens isn’t the same as a file in the current required format.

Enforcement

CMS decides who is compliant

CMS can look into complaints, review outside analyses, run audits, ask for documents or certifications, and do a full review.

If CMS decides a hospital isn’t following the rule, it can send a written warning. For a serious violation it can ask the hospital for a corrective action plan that lists the fixes and a timeline. If the hospital doesn’t respond, or doesn’t finish the approved plan, CMS can fine it and make the fine public.

The rule says these steps usually, but not always, happen in that order. CMS can also publish its findings and outcomes. When the same problem shows up across a health system, it can work with the system’s leaders.

Four steps CMS can take, from looking into a problem to a public fine, shown as a rising staircase. CMS looks into itComplaint or audit Written warningA formal notice Corrective planThe fixes and a timeline Fine, made publicA civil monetary penalty Usually in this order, but not always. A fine only follows if a hospital doesn’t answer or doesn’t finish its plan.
What CMS can do if it decides a hospital isn’t following the rule. This project can’t take any of these steps.

This tracker

The tracker checks one slice of the rule

The automated check asks one thing: can an outsider find and read the hospital’s price file?

It starts with a hospital’s known website and asks for the standard pointer file. It matches an entry in that file to the hospital, follows the price file link, and reads enough of the file to check basic details. It looks at whether the file can be reached, which template version it names, and when it was last updated.

It doesn’t check every row. It doesn’t confirm that all negotiated prices are there, judge whether they are accurate, compare them with contracts, or test the patient lookup tool.

Some hospitals are matched to a file through reviewed evidence even when no usable pointer file exists. Those results keep their source and review notes. They aren’t presented as if the file had been found the standard way.

Reading results

Each label says what was observed

File located
A price file opened and passed the tracker’s checks for access, template version and freshness. The prices inside it were not verified.
Issue observed
A specific problem was observed, such as no pointer file, a dead link to the price file, an update date over a year old, or an outdated template. This is a note for review, not a legal finding.
Request denied
The website or file refused the tracker’s automated request. That prevents a result, so it is kept apart from problems seen in the file itself.
Not assessed
There was no usable website, the site didn’t respond, or a health-system pointer file couldn’t be confidently matched to this hospital.
Exempt
The project treats this hospital as outside the normal check. Most are covered by 45 CFR 180.30(b): federal hospitals, Indian Health Program hospitals and some state hospitals. Facilities with dated evidence that they have closed are listed here too.

Results are a snapshot on a date. Hospitals can swap files, fix links, change websites or reorganize after the check. The tracker keeps denied and not-assessed hospitals in view so you can see where the check couldn’t reach.

Sources

Official references

Previous Price files What is in the price file and what its prices mean. Next Pointer files How a small text file makes a hospital’s price file easy to find.