Hospital price transparency
How to Check Whether Your Hospital Machine-Readable File Is Compliant
Short answer. Run the file through the CMS HPT validator, then check the 2026-specific elements by hand: the attestation and responsible official, the Type 2 NPI(s), and dollar allowed amounts with a count for every percentage or algorithm charge. Validators check structure against the CMS template; they cannot tell you whether the data is complete or true.
Step 1: Get the current file and template
Download the file exactly as the public sees it from your hospital website. CMS publishes the MRF templates and data dictionary in its hospital-price-transparency repository. Compare your file layout to the template version your file claims.
Step 2: Run the CMS validator
CMS maintains an open-source validator, the HPT MRF validator (CMSgov/hpt-tool). It checks that a CSV or JSON file matches the template and reports structural errors. A clean validator result means the structure is valid. It does not show that every payer, plan and item is present.
Step 3: Check the 2026 elements
- Attestation and official. The file contains the attestation statement and the name of the CEO, president or senior official overseeing the data.
- Type 2 NPI. Every active organizational NPI with a primary taxonomy code beginning 28 or 27 is listed.
- Allowed amounts. For each payer-specific charge that is a percentage or algorithm, the median, 10th and 90th percentile allowed amounts and the count of allowed amounts are present, drawn from 12 to 15 months of remittances.
- Old field gone. The estimated allowed amount is no longer used.
Source: CMS fact sheet.
Step 4: Read the blanks correctly
Blank cells are not automatically a violation. CMS says that when a charge is a percentage or algorithm and the hospital has no claims in the lookback period, it must encode 0 as the count, leave the three allowed amounts blank, and explain the insufficient remittance history in the notes field. Zero-dollar remittances are excluded from the count. Source: CMS FAQs.
Step 5: Spot-check against your contracts
Pick a sample of high-volume services and compare the file to your payer contracts and remittances. Check that the payer and plan names match, that percentage and algorithm charges have the supporting information needed to derive a dollar amount, and that the last-updated date is current.
When to bring in help
A manual check scales poorly across thousands of items and many payers. An automated audit can run the same checks on every row each time the file is regenerated.
Frequently asked questions
Is passing the CMS validator enough?
No. The validator tests structure against the template. Completeness, accuracy and the 2026 data elements still need to be reviewed.
Are blank cells in my file a problem?
Not necessarily. CMS explains in its FAQs that blanks can be correct, for example where no remittance data exists. The notes field must explain why.
How often should the file be checked?
Check it whenever the file is regenerated, and whenever contracts or CMS requirements change.
Sources
- CMS HPT MRF validator (GitHub)
- CMS hospital-price-transparency templates and data dictionary (GitHub)
- CMS: CY 2026 final rule fact sheet
- CMS: Hospital Price Transparency FAQs
Related guides
YieldGuard audits hospital machine-readable files against the current CMS requirements. Request Compliance Assessment