Hospital price transparency
Choosing the rest to reach 300
The rule does not always mean "70 plus 230". It requires the CMS-specified services the hospital provides, plus enough hospital-selected shoppable services for a combined total of at least 300. When fewer than 70 of the specified services are offered, more than 230 hospital-selected services may be needed.
For example, a hospital offering 60 of the CMS-specified services would need at least 240 additional shoppable services to reach 300, assuming it offers that many in total. This is an illustration of the count rule, not a hospital finding. A hospital providing fewer than 300 shoppable services lists as many as it provides and identifies the CMS-specified services it does not offer.
In selecting the additional services, 45 CFR 180.60(a)(1)(i) says the hospital must consider the rate at which it provides and bills for each service. CMS explains that the selected services should be commonly provided to the hospital's patient population. A list chosen only because its data is easy to export is not the selection method the rule describes.
Recommended workflow: establish the CMS-service mapping first, review service utilization and billing, select the additional schedulable services, then attach the applicable ancillary charges. Keep the service-selection decision separate from the price fields. A complete count does not show that the associated charge information is complete.