A hospital price transparency compliance program is the set of named owners, procedures and records that keep a hospital's machine-readable file of standard charges and shoppable services display current under 45 CFR Part 180. Integral Healthcare Solutions (IHS) drafts those procedures and logs for the teams that own the work.
IHS is a consulting firm, not a law firm. The hospital publishes the file and answers CMS.
Last updated: November 2026
What does 45 CFR Part 180 require of a hospital?
Part 180 requires a hospital to make public a machine-readable file of all standard charges for all items and services, and a consumer-friendly list of standard charges for a limited set of shoppable services (180.40). The text is 45 CFR Part 180 in the current eCFR Title 45 file at GovInfo (file built November 4, 2026; Title 45 last amended November 3, 2026), opened November 5, 2026.
Under 180.30(b), CMS deems Federal and State hospitals to comply, including but not limited to federally owned hospital facilities, hospitals operated by an Indian Health Program and State forensic hospitals that treat exclusively individuals in the custody of penal authorities.
The machine-readable file
- Standard charges. The file carries five: gross charge, payer-specific negotiated charge, de-identified minimum and maximum negotiated charges and discounted cash price (180.20).
- Locations. A hospital location operating under a single hospital license (or approval) that has a different set of standard charges than the other locations under that license must separately make public its own charges (180.50(a)(2)).
- Payer-specific charges. The file shows payer and plan names, the method used to establish the charge, and whether it is a dollar amount or based on a percentage or algorithm. For a percentage or algorithm charge the file must also describe it and, beginning January 1, 2026, encode the 10th percentile, median and 90th percentile allowed amounts in dollars and the number of allowed amount remittances used (180.50(b)(2)(ii)).
- Allowed-amount window. Each allowed amount is computed from what the hospital has historically received from a third party payer for the item or service over no less than 12 and no longer than 15 months before the file is posted (180.20).
- Attestation and named official. Beginning January 1, 2026, the hospital attests in the file as 180.50(a)(3)(iii) sets out and encodes the name of its chief executive officer, president or senior official designated to oversee the encoding (180.50(a)(3)(iv)).
- Identifiers. Beginning January 1, 2026 the file lists the hospital's Type 2 (organizational) NPIs (180.50(b)(2)(i)(A)).
- Format and posting. Beginning July 1, 2024 the file conforms to a CMS template layout, data specifications and data dictionary (180.50(c)(2)). It must be digitally searchable (180.50(d)(4)) and sit on a public website free of charge, without an account, password or personal identifying information. Beginning January 1, 2024 the site maintains a .txt file in the root folder and a footer link labeled Price Transparency (180.50(d)).
The shoppable services display
The hospital makes public the payer-specific negotiated charge, discounted cash price and de-identified minimum and maximum negotiated charges for as many of the 70 CMS-specified shoppable services as it provides, plus enough hospital-selected services for a combined total of at least 300, or as many as it provides if that is fewer than 300 (180.60(a)(1)). CMS deems a hospital to meet the section if it maintains an internet-based price estimator tool that estimates the same services, gives the consumer an estimate of what the consumer will be obligated to pay the hospital at the time of use, and is prominently displayed, free, without registration (180.60(a)(2)).
How does CMS enforce Part 180, and when can a penalty follow?
If CMS concludes a hospital is noncompliant, it may take these actions, generally but not necessarily in this order (180.70(b)):
- A written warning notice of the specific violations, with an acknowledgement of receipt by the deadline in the notice.
- A request for a corrective action plan if the noncompliance is a material violation (180.80). Material violations include failing to publish what 180.40 requires, or to do so in the form and manner 180.50 and 180.60 require.
- A civil monetary penalty, publicized on a CMS website, if the hospital fails to respond to the plan request or to comply with the plan (180.70(b)(3)). Failing to respond includes missing the form, manner or deadline in the notice (180.80(d)).
Beginning January 1, 2022, the penalty maximum per day is 300 dollars for a hospital with 30 beds or fewer, the number of beds times 10 dollars for 31 through 550 beds, and 5,500 dollars above 550 beds, even if the hospital violates several requirements (180.90(c)(2)(ii)). The amounts are adjusted annually with the OMB multiplier (180.90(c)(3)), so current figures may differ. A hospital that does not request a hearing within 30 calendar days of the penalty notice (extended to the end of the next business day if the 30th day is a weekend or Federal holiday) has no right of appeal unless it shows good cause (180.110). Within 30 calendar days of the notice date the hospital may instead waive its hearing right in writing for a 35 percent cut, unless CMS imposed the penalty for failing to make public the file or the shoppable services list; the waiver also gives up the cut and the appeal for later penalties on continuing violations (180.90(c)(4)). Without a hearing request, payment is due within 60 calendar days of the notice, extended to the end of the next business day if the 60th day is a weekend or Federal holiday (180.90(d)).
Who needs a price transparency compliance program and what triggers it?
Every hospital within the 180.20 definition must update annually (180.50(e)) unless 180.30(b) deems it compliant. These events start the work.
- The annual update date in 180.50(e).
- The January 1, 2026 requirements: the attestation, the named official, the hospital's Type 2 (organizational) NPIs and the percentile allowed amounts.
- A CMS warning notice or corrective action plan request (180.70), or a penalty notice, which starts a 30-calendar-day hearing or waiver decision (180.90 and 180.110).
How does IHS help a hospital with price transparency compliance?
IHS ties each recurring Part 180 task to a named owner, a date and a record. Thomas G. Goddard, JD, PhD, IHS founder and former URAC Chief Operating Officer and General Counsel, leads the work in Compliance Services.
What IHS drafts
- A data-owner map that assigns each data element in 180.50(b)(2) and 180.60(b) to a person.
- An annual update procedure and a quarterly check (an IHS method, not in the text).
- An attestation tracker for 180.50(a)(3)(iii) and (iv), including the named official.
- An allowed-amount worksheet recording the look-back window and remittance count used for each percentage or algorithm charge.
- A file-location checklist, a shoppable-services selection log and an evidence log of update dates and CMS notices.
What you supply and the real limit
You supply the charge and payer data, the allowed-amount calculations, your website, your shoppable services selection and the file. IHS does not build, encode or host the file, does not decide whether your file complies and does not respond to CMS for the hospital.
What should a hospital have ready for a price transparency review?
- Your machine-readable file, the date of its last update, the attestation in it, the official named in it and the Type 2 NPIs it lists (180.50(a)(3), (b)(2)(i)(A) and (B) and (e)).
- Each location under one license that has different standard charges from the other locations (180.50(a)(2)), and the CMS template version your file conforms to (180.50(c)(2)).
- For each percentage or algorithm charge, the allowed amounts, look-back window and remittance count (180.50(b)(2)(ii)).
- The .txt file in your website root folder, a screenshot of the Price Transparency footer link, and a test that the file is searchable and downloads without an account (180.50(d)).
- Your shoppable services list and how each was chosen, or your price estimator tool (180.60(a)).
- Any CMS warning notice, corrective action plan request or penalty notice (180.70 and 180.90).
The free introductory call is where IHS walks through the list with you.
How does a procedure and evidence log compare with other approaches?
| Approach | What it covers |
|---|---|
| Procedure and evidence log | Owners, dates, checks and records around the file; no file build, no legal advice. |
| Software that builds the file | Generates the file. IHS has not reviewed any product. |
| Legal review | The hospital's counsel reads Part 180 and answers any CMS notice. |
What does a price transparency compliance program cost?
- Government amounts. Part 180 carries no compliance fee, only the penalties above, adjusted annually; verify current amounts with CMS.
- Consulting fees. IHS scopes each engagement after a free introductory call. Scope drivers are the number of locations with different standard charges, the payers and plans, how many charges rest on a percentage or algorithm, and whether an owner map and update calendar exist.
What this is not
- It is not legal advice; IHS is not a law firm.
- It does not guarantee any outcome with CMS, and IHS does not certify that a file complies.
Frequently asked questions
What is the hospital price transparency rule?
It is 45 CFR Part 180. A hospital must make public a machine-readable file of all standard charges for all items and services and a consumer-friendly list of standard charges for a limited set of shoppable services (180.40). Section 180.30(b) deems Federal and State hospitals compliant.
What goes in the machine-readable file?
The file lists the five standard charges defined in 180.20 for all items and services, with the data elements in 180.50(b)(2).
How often must the file be updated?
At least once annually (180.50(e)). The file carries the date of its most recent update (180.50(b)(2)(i)(B)).
What is the shoppable services requirement?
The hospital makes public four standard charges for as many of the 70 CMS-specified shoppable services as it provides, plus enough hospital-selected services for a combined total of at least 300, or as many as it provides if that is fewer than 300 (180.60(a)(1)).
What must be on the hospital website?
Beginning January 1, 2024, the site hosting the file must maintain a .txt file in the root folder. It must also maintain a footer link, including but not limited to the homepage, labeled Price Transparency that links directly to the page hosting the link to the file (180.50(d)(6)).
What changed on January 1, 2026?
Beginning January 1, 2026, the hospital attests in its file that, to the best of its knowledge and belief, it has included all applicable standard charge information in accordance with 45 CFR 180.50 and the information is true, accurate and complete as of the date in the file, and that it has included all payer-specific negotiated charges that can be expressed as a dollar amount. For charges that cannot be expressed in dollars or are not knowable in advance, it attests that the charge rests on a contractual algorithm, percentage or formula that precludes a dollar amount and that it has provided all necessary information available to it for the public to derive the dollar amount (180.50(a)(3)(iii)). It also encodes the name of its chief executive officer, president or senior official designated to oversee the encoding (180.50(a)(3)(iv)). Since the same date the file also lists the hospital's Type 2 (organizational) National Provider Identifiers (180.50(b)(2)(i)(A)) and, for each payer-specific negotiated charge based on a percentage or algorithm, the 10th percentile, median and 90th percentile allowed amounts in dollars and the number of allowed amount remittances used (180.50(b)(2)(ii)(C)(2)).
What happens if CMS finds a violation, and how large can the penalty be?
CMS may issue a warning notice, request a corrective action plan if the noncompliance is a material violation, and impose a civil monetary penalty if the hospital fails to respond to the plan request or to comply with the plan (180.70(b)). The daily maximum depends on bed count (180.90(c)).
Does IHS build the file or respond to CMS?
No to both. IHS drafts the procedures and records around the file, such as the data-owner map and attestation tracker. The hospital builds and publishes the file and, with its counsel, answers any CMS notice.