What the Hospital Price Transparency Rule requires
The Hospital Price Transparency Rule (45 CFR Part 180), which took effect January 1, 2021, requires every hospital that participates in Medicare to publish a machine-readable file containing its standard charges. This is not optional. Hospitals that do not comply face civil monetary penalties enforced by the Centers for Medicare and Medicaid Services.
The rule defines five categories of standard charge that each file must include for every item or service the hospital provides:
- Gross charge. The chargemaster price before any discounts or adjustments. This is the starting number that almost no one actually pays.
- Discounted cash price. The rate the hospital charges patients who pay out of pocket without using insurance.
- Payer-specific negotiated rate. The rate the hospital has agreed to accept from a specific insurance plan for a specific service. This is the most useful number for most patients.
- De-identified minimum negotiated rate. The lowest negotiated rate for this service across all payers, without identifying which payer pays it.
- De-identified maximum negotiated rate. The highest negotiated rate across all payers.
The payer-specific negotiated rate column is what distinguishes this requirement from earlier transparency efforts. For the first time, hospitals are required to disclose not just that they have negotiated contracts, but what those contracts actually say, by insurer and by plan.
What the file looks like
Hospitals can publish their files in any machine-readable format. JSON and CSV are most common. Some hospitals publish JSON files that are hundreds of megabytes. Others publish clean spreadsheets organized by CPT code. The format varies significantly by hospital and by the vendor they use for compliance.
Within the file, each row (or record) typically contains:
- A billing code (CPT, HCPCS, DRG, or revenue code)
- A plain-language description of the service
- The five standard charge types listed above
- For payer-specific rates: the payer name, the plan name, and the negotiated rate
For a hospital with 20 insurance contracts and 10,000 service lines, a complete file can contain hundreds of thousands of rows. That scale is by design: the rule requires disclosure at the plan level, not just by insurer.
How to find your hospital’s file
CMS maintains a hospital price transparency resource at cms.gov/hospital-price-transparency, which includes guidance on where to look and links to enforcement actions against non-compliant hospitals.
The most direct path is usually the hospital’s own website. Look for:
- A page titled “Price Transparency,” “Standard Charges,” or “Patient Financial Services”
- A link in the footer or billing FAQ section
- A direct search on the hospital’s domain for “machine-readable file” or “standard charges”
If the hospital does not have a clearly accessible file, that may itself be a compliance violation. CMS has issued civil monetary penalties to hospitals for failing to publish or maintain accessible files.
How to use the file to dispute a charge
Once you have the file, the process is straightforward:
- Identify the CPT code or service description for the charge you are disputing. This comes from your itemized bill.
- Search the machine-readable file for that code.
- Find the row corresponding to your insurance plan and plan name.
- Compare the negotiated rate in the file to what you were billed.
If your bill charges you more than the payer-specific negotiated rate for your plan, you have a concrete, documented discrepancy. Your dispute letter can cite the exact rate from the published file, reference 45 CFR Part 180, and request correction to the contracted amount.
This is a stronger dispute basis than most patients use. The hospital has publicly attested to the negotiated rate. A charge that exceeds it is inconsistent with the published contract data.
Common gotchas
Not every hospital publishes a complete or accurate file. CMS enforcement data shows ongoing non-compliance across hundreds of hospitals. If the file you find is outdated, missing your insurer, or does not contain payer-specific rates, document that absence and escalate through your insurer’s appeals process instead.
Some hospitals publish files that technically comply but are structured to be difficult to use: inconsistent column names, nested JSON without documentation, or plan names that do not match what appears on your insurance card. If you cannot match your plan, call the hospital’s billing department and ask them to identify which row in the file corresponds to your specific plan. Their answer creates a record.
The negotiated rate in the file is also not necessarily the “allowed amount” on your Explanation of Benefits. Allowed amounts reflect the negotiated rate applied to a specific claim after claim processing. The MRF rate is a contract floor. In practice the two numbers should be consistent, but discrepancies occur. When they do, the EOB and the MRF together are your evidence.
What to do if you cannot open the file
Large JSON files require a tool to parse. If you are comfortable with spreadsheet software, many JSON-to-CSV converters are freely available online. If not, calling the hospital’s price transparency line and asking them to look up the negotiated rate for your CPT code and plan in writing is a legitimate alternative. The hospital is required to provide this information; the machine-readable file is one mechanism, not the only one.
For the context behind why the gap between gross charges, negotiated rates, and what patients actually owe is so large, see our guide to why your bill exceeds your insurer’s negotiated rate.