Key Price Transparency Updates Hospitals Must Comply with by April 1, 2026

CMS has finalized another significant round of updates to the hospital price transparency requirements, including adopting a revised standardized template that hospitals must use going forward. Although the new requirements were effective January 1, 2026, CMS delayed enforcement of the new requirements until April 1, 2026 to provide hospitals with additional time to implement the changes. To help hospitals prepare for the April 1 deadline, we have summarized three key elements of the updates:

1. Replacement of Estimated Allowed Amount with Actual “Allowed Amounts”

CMS will require hospitals adopt yet another new template (version 3.0.0), which replaces the “estimated allowed amount” with columns based upon actual dollar-based data. When a payer-specific negotiated charge is based on a percentage or algorithm, hospitals must encode the median, 10th percentile, and 90th percentile allowed amounts, along with the total number of remittances used to determine the median and calculate the 10th and 90th percentiles.

• “Median allowed amount’’ defined as the median of the total allowed amounts the hospital has historically received from a third-party payer for an item or service for a time period at least 12 months and no longer than the 15 months prior to posting the machine-readable file. Should the calculated median fall between two observed allowed amounts, the median allowed amount is the next highest observed value.

o NOTE: Median is not the average. The median is the middle value in a dataset when arranged in order, representing the central point where half the data points are above it and half are below; it’s found by selecting the middle number for odd sets or averaging the two middle numbers for even sets.

• ‘‘Tenth (10th) percentile allowed amount’’ defined as the 10th percentile of the total allowed amounts the hospital has historically received from a third-party payer for an item or service for a time period at least 12 months and no longer than the 15 months prior to posting the machine-readable file. Should the calculated percentile fall between two observed allowed amounts, the 10th percentile allowed amount is the next highest observed value.

• ‘‘Ninetieth (90th) percentile allowed amount’’ defined as the 90th percentile of total allowed amounts the hospital has historically received from a third-party payer for an item or service for a time period at least 12 months and no longer than the 15 months prior to posting the machine-readable file. Should the calculated percentile fall between two observed allowed amounts, the 90th percentile allowed amount is the next highest observed value.

The “total allowed amount” used in each definition represents the hospital’s gross charge minus all contractual adjustments. It includes both the portion paid by the health plan for the specific payer–plan combination and any portion paid by the patient, if applicable. In other words, it reflects the total reimbursement the hospital actually received for the item, service, or service package. CMS requires hospitals to calculate this “total allowed amount” using data from EDI 835 ERA transactions, drawn from a lookback period of at least 12 months and no more than 15 months before the machine-readable file is posted.

2. New Attestation Requirement

Although the current machine-readable file includes an affirmation statement, CMS has modified the language to require an attestation that the hospital has included all applicable payer-specific negotiated charges in dollars that can be expressed as a dollar amount. For payer-specific negotiated charges that cannot be expressed as a dollar amount or are not knowable in advance, the attestation must confirm that the hospital has included in the machine-readable file all necessary information available to the hospital for the public to be able to derive a dollar amount, including, but not limited to, the specific fee schedule or components referenced in such percentage, algorithm, or formula.

Hospitals are also required to include the name of the hospital CEO or other senior official designated to oversee the encoding of true, accurate, and complete data.

3. Must Include Hospital National Provider Identifier(s) (NPIs)

Hospitals must now encode their organizational (Type-2) NPI(s) associated with an active hospital taxonomy code in the MRF. This is meant to support standardization and improve comparability with other provider data.

CMS claims that the changes reflect its continued focus on improving the accuracy and comparability of hospital price transparency data. Hospitals can use the delayed enforcement period to carefully review their machine-readable files and data sources, CMS guidance, and confer with experienced counsel to ensure compliance with the Hospital Price Transparency Rules.

“Key Price Transparency Updates Hospitals Must Comply with by April 1, 2026”

Louisiana Hospital Association Impact Law Brief, Vol. 41, No. 1. January 2026

 Written by  Heather Arrington