Hospital price transparency
The 2026 Hospital Price File Gap Types, Explained
Short answer. Under the 2026 rule, the gaps most tied to the new requirements are: percentage or algorithm charges with no dollar allowed amounts, a missing allowed-amount count, no Type 2 NPI, an old affirmation statement or no named official, and blank or zero cells with no explanation. CMS treats some blanks as correct when the notes field explains why.
Gap 1: Percentage or algorithm charge with no dollar allowed amounts
If a payer-specific negotiated charge is a percentage or algorithm that cannot be fully calculated as a dollar amount, and the hospital has claims in the lookback period, the file must show the median, 10th and 90th percentile allowed amounts in dollars. An empty set of those fields is a gap. Source: CMS FAQs.
Gap 2: Missing count of allowed amounts
The count of allowed amounts used in the calculation is a required element alongside the three percentiles. A file that has the dollar values but not the count is incomplete.
Gap 3: Allowed amounts built from the wrong period or data
CMS requires EDI 835 remittance advice or an equivalent source, and a lookback of at least 12 and at most 15 months before posting. If a calculated percentile falls between two observed values, use the next highest observed value. Zero-dollar remittances are excluded from the count. Source: CMS fact sheet.
Gap 4: No Type 2 NPI
The file must list every active Type 2 NPI associated with a primary taxonomy code starting with 28 or 27. A missing or invalid value is a gap. Source: CMS fact sheet.
Gap 5: Old affirmation or no responsible official
The affirmation statement was replaced by an attestation, and the file must include the name of the CEO, president or senior official designated to oversee the data. A file still using the old statement, or without the name, does not meet the 2026 requirement.
Gap 6: Blanks and zeros with no explanation
If there are no claims in the lookback period, CMS says to encode 0 as the count, leave the allowed amounts blank, and explain it in the notes field. A blank without that explanation, or a placeholder value in place of a real one, is a gap. Source: CMS FAQs.
Frequently asked questions
Does a blank cell mean the hospital is non-compliant?
Not by itself. CMS says blanks can be correct where there is no data to encode, provided the file explains it.
Which gap is most likely to be new in 2026?
Gaps 1 to 5 all stem from elements that became effective January 1, 2026: dollar allowed amounts and counts, the attestation and official, and Type 2 NPIs.
Sources
- CMS: CY 2026 final rule fact sheet
- CMS: Hospital Price Transparency FAQs
- Federal Register: CMS-1834-FC
Related guides
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