Hospital price transparency
An enforcement-response playbook
An enforcement response starts with the notice, not with a generic promise to fix the website. Preserve the received notice and identify the hospital location, cited requirements, required acknowledgement, CAP instructions, deadlines and contact route. This is a recommended intake workflow; the duties come from the notice and applicable regulation.
Create a separate work item for each deficiency and assign an owner who can change the actual public disclosure or source data. A CAP must describe corrective actions or processes and a completion timeframe, and is subject to CMS review and approval. Keep proof of submission distinct from proof that the correction is live and works.
Retest the public URL, file or consumer-facing result involved in each finding. Preserve dated evidence and record what remains uncertain. CMS's FAQ allows an authorized official to send detailed written questions about notice deficiencies to HPTCompliance@cms.hhs.gov and recommends hospital counsel or compliance officials. A technical reviewer should not invent a legal position or promise an extension.
If a CMP arrives, route it promptly to counsel. Under 45 CFR 180.110, a hospital generally has 30 calendar days from the notice to request a hearing; a weekend or federal-holiday 30th day extends to the next business day. A hearing waiver and any associated reduction affect rights and have specific exclusions; they are not routine administrative acknowledgements. Track the applicable payment deadline separately. This playbook does not authorize anyone to waive rights, pay a penalty or speak for a hospital.
Sources
- 45 CFR 180.70
- 45 CFR 180.80
- 45 CFR 180.90
- 45 CFR 180.100
- CMS HPT FAQs, enforcement and appeals
- 45 CFR 180.110, failure to request a hearing