2026 HPT GUIDE
2026 Hospital Price Transparency Requirements: An MRF Readiness Guide
CMS began enforcing the new and revised 2026 hospital price-transparency machine-readable-file requirements on April 1, 2026. This guide turns the technical changes into a review sequence for hospital compliance, revenue-cycle, and data teams.
What changed
The CMS v3.0 data dictionary adds an attestation statement and attester name, organizational Type 2 NPIs, and actual allowed-amount statistics. It also removes the former affirmation statement and estimated allowed amount.
- Attestation statement and attester name
- Type 2 organizational NPI for applicable hospital locations
- Median, 10th percentile, 90th percentile, and count of allowed amounts
- Current CMS template version and conditional-field requirements
A practical readiness sequence
Start with accessibility and format, then test schema conformance, conditional requirements, field-level completeness, and internal consistency. Preserve the exact file, hash, validation time, and ruleset used for review.
- Confirm the public URL is reachable without authentication
- Detect JSON, wide CSV, or tall CSV
- Validate against the current CMS data dictionary
- Review deficiencies in context rather than treating a pass as legal advice
- Record remediation and final review evidence
What technical validation cannot prove
A schema-conforming file is not automatically accurate or complete. Technical validation cannot determine whether source pricing, payer mappings, claim-history calculations, or legal interpretations are correct. Those remain human and organizational responsibilities.