By: Catherine Moore

Hospital Price Transparency requirements were established to provide patients with meaningful access to healthcare pricing information and to promote informed decision-making. Since 2021, hospitals have been required to publicly post both a machine-readable file containing standard charges and consumer-friendly pricing information for certain services. While initial enforcement efforts focused largely on education, recent Centers for Medicare & Medicaid Services (“CMS”) activity demonstrates a continued commitment to actively monitoring compliance and imposing penalties where deficiencies persist. Although the requirements have been in place since 2021, with new requirements taking effect as recently as January 1, 2026, CMS now is leveraging automation to complete hospital reviews quickly and identifies hospitals to review based on a web scraper tool. CMS performs at least 200 comprehensive hospital reviews “quickly, accurately and consistently” each month.

For Louisiana hospitals, the recent enforcement activity offers several important lessons. First, price transparency compliance should not be viewed as a one-time implementation project but rather as an ongoing compliance obligation that requires regular review and oversight. Hospitals should establish clear internal ownership of transparency requirements, routinely test website functionality, validate pricing data, and ensure that machine-readable files are updated as contractual rates and services change. Second, organizations should be prepared for regulatory scrutiny by maintaining documentation of their compliance efforts, audits, and corrective actions. As enforcement efforts continue to mature, hospitals that take a proactive approach will be better positioned to avoid costly penalties, minimize operational disruption, and demonstrate a meaningful commitment to transparency.

Hospitals that receive a Warning Notice or request for a Corrective Action Plan should act promptly. Failure to adequately address identified deficiencies can escalate enforcement risk and potentially lead to the imposition of civil monetary penalties.