Industry Watch Alert
Podcast Episode
Key Takeaways
1. CMS compliance deadline of January 1, 2025, required hospitals to implement new, standardized pricing disclosures.
2. Federal agencies are intensifying enforcement efforts, significantly increasing penalties for non-compliance.
3. Employers, providers, and insurers must closely align to maintain compliance and avoid penalties.
Key Takeaways
Recent federal actions strengthen hospital and prescription drug price transparency.
- CMS compliance deadline of January 1, 2025, required hospitals to implement new, standardized pricing disclosures.
- Federal agencies are intensifying enforcement efforts, significantly increasing penalties for non-compliance.
- Employers, providers, and insurers must closely align to maintain compliance and avoid penalties.
The Impact
On May 22, 2025, the U.S. Departments of Labor, Health and Human Services, Treasury, and the Centers for Medicare & Medicaid Services (CMS) announced major advancements in healthcare price transparency. These regulatory enhancements directly impact hospitals, insurers, employers, and healthcare providers nationwide.
The compliance deadline of January 1, 2025, required hospitals to:
Provide a machine-readable file (MRF) with actual, not estimated, prices for all hospital items and services.
Display at least 300 shoppable services in a consumer-friendly format.
Include new standardized data elements such as estimated allowed amounts, drug unit and type of measurement, and billing code modifiers.
Affirm the accuracy and completeness of all posted data in a signed statement.
These requirements are part of CMS’s broader effort to improve accessibility, accuracy, and consistency in healthcare pricing.
Additionally, the Departments issued Requests for Information (RFIs) to solicit feedback on improving transparency practices—especially regarding prescription drug machine-readable files and the completeness of hospital pricing data. These actions demonstrate the agencies’ intention to continue tightening compliance expectations.
Penalties for non-compliance have substantially increased, from approximately $100,000 per hospital to over $2 million annually for large hospitals as of 2022. This underscores the importance of prompt and complete compliance.
These federal actions reinforce ACA mandates around preventive services, mental health parity, and transparency in cost-sharing, creating a unified framework for consumer protection and informed healthcare decision-making.
FAQ
Q1: What major changes were required by January 1, 2025?
Hospitals were expected to publish actual pricing data, follow CMS-standardized formats, include specific new data elements, and provide written affirmations of data accuracy.
Q2: How have penalties changed for non-compliance?
Maximum penalties for hospital non-compliance have increased dramatically, potentially exceeding $2 million annually for large institutions.
Q3: What action steps should healthcare leaders take immediately?
Healthcare leaders must review their compliance status, ensure their pricing files meet CMS requirements, and monitor ongoing regulatory updates to mitigate risk.
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Sources
CMS Press Release – May 22, 2025
Departments of Labor, Health and Human Services, Treasury Announce Move to Strengthen Healthcare Price Transparency
https://www.cms.gov/newsroom/press-releases/departments-labor-health-and-human-services-treasury-announce-move-strengthen-healthcare-priceCMS Hospital Price Transparency Resources
Key requirements, updates, templates, and technical guidance
https://www.cms.gov/priorities/key-initiatives/hospital-price-transparency/resourcesCMS Hospital Price Transparency – Accuracy and Completeness RFI
Request for information on hospital data accuracy and completeness enforcement
https://www.cms.gov/priorities/key-initiatives/hospital-price-transparency/accuracy-and-completeness-rfiEBSA ACA Implementation FAQs – Part 70
Clarifies ACA requirements including mental health parity and preventive service mandates
https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-70DOL RFI – Prescription Drug Machine-Readable File Requirement
Seeks stakeholder input on improving transparency around prescription drug pricing
https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/affordable-care-act/for-employers-and-advisers/rfi-regarding-prescription-drug-machine-readable-file-requirement-in-the-transparency-in-coverage-final-rule.pdf
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