On November 21, 2025, CMS finalized updates to Hospital Price Transparency regulations in the CY 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Final Rule. These changes will affect the information hospitals must disclose in their machine-readable files (MRFs). These changes will become effective on January 1, 2026, with enforcement beginning on April 1, 2026.
What are the major Price Transparency changes included in the CY 2026 OPPS Final Rule?
Beginning on January 1, 2026, Hospitals must utilize electronic remittance advices (ERAs) to calculate the allowed amounts for the median, 10th, and 90th percentile for rates that are expressed as percentages or algorithms from the previous 12 to 15 months before posting the MRF.
Hospitals will be required to report the median, 10th percentile, and 90th percentile allowed amounts when a payer-specific negotiated charge is based on a percentage or an algorithm. Hospitals will also be required to report the number of allowed amounts that were used to calculate the median and percentile values. These values will replace the “estimated allowed amount” field in the current MRF format.
The attestation statement in the MRF must be updated to confirm that the hospital “has included all applicable payer-specific negotiated charges in dollars that can be expressed as a dollar amount, and for payer-specific negotiated charges that cannot be expressed as a dollar amount in the MRF or are not knowable in advance, the hospital has provided in the MRF 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.” (CMS-1834-F, Hospital Price Transparency Policy Changes). Hospitals are also required to include the name of the hospital’s senior official designated to oversee the encoding of true, accurate, and complete data.
Hospitals must also include all active type 2 NPIs (National Provider Identifiers) in a newly created MRF data element for any NPIs associated with the hospital or hospital units.
Considerations for Compliance with the New Price Transparency Requirements
- Can your system retrieve payer remittance (i.e., ERAs/835) files for the 12 to 15-month period preceding the publication of the MRF?
- Do you have tools or processes to calculate median and percentile values for payer-specific negotiated charges based on a percentage or an algorithm?
- Do you have resources available to update the hospital MRFs to include the newly required data elements, such as median and percentile values, number of service line items included in the percentile calculation, hospital NPIs, attestation statement modifications, etc?
Contact Blue & Co.
This is not an exhaustive list of all items required for compliance. Blue & Co. can assist your hospital with Price Transparency compliance. Our team can analyze your hospital’s ERA files, perform the calculations necessary to comply with the median and percentile requirements, and ensure that the MRF is compliant with the new NPI and attestation requirements before the April 1, 2026, enforcement deadline. Contact our experts today.
Scott Treida, CPC, MT (ASCP), Director
