Hospital price transparency
Multi-system consolidation problems
Health systems consolidate hospitals that came with different chargemasters, different payer contracts and different posting habits. The rule does not care about the org chart: it cares about licenses and standard charges. Each hospital location operating under a single license that has a different set of standard charges from the other locations under that license must separately make public the charges that apply to it.
The FAQ's naming guidance follows the same logic. Locations sharing an EIN and legal name but posting different charges need distinguishable files; locations with identical charges follow the shared-file guidance. Getting this wrong creates files that are individually plausible and collectively wrong.
The consolidation failure is usually temporal. The acquired hospital's file keeps its old update cycle, its old vendor and its old naming, and nobody owns bringing it into the system standard. Months later the system website links a file that reflects a hospital that no longer operates that way.
The attestation raises the stakes. Every file under every license now names a senior official who affirms its completeness. In a system, that is either one official affirming many files they have never seen, or many officials with unclear coverage. Neither works without an inventory: every license, every location, every file, one named owner each.