Hospital price transparency
Who should sign the attestation
The CY 2026 OPPS/ASC final rule requires the file to encode the name of the hospital's chief executive officer, president, or a senior official designated to oversee the encoding of true, accurate and complete data. The schema is explicit that this is a first and last name - a person, not a title or a department. CMS has said the title itself is flexible: what matters is the role, not the business card.
CMS expects one thing of the named person: they should be the same individual who would submit a certification of the file's accuracy and completeness to CMS if CMS requested one during monitoring, under 45 CFR 180.70(a)(2)(iv). Naming someone who could not plausibly sign that certification misses the point of the requirement.
The attester is not expected to build the file. CMS acknowledges the senior official may not be directly involved in MRF development. But the attester must be able, as part of hospital governance, to consult the people who are - a compliance officer, a revenue cycle leader - and get real answers before the name goes in.
Practical test for a designation: if CMS asked for the certification tomorrow, would this person know who to call, and would those calls have answers?
Sources
Related guides
YieldGuard audits hospital machine-readable files against the current CMS requirements. Request Compliance Assessment