May 2025 CMS Update: Are Your Price Transparency Files Still Compliant?

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What’s New as of May 22, 2025

On May 22, 2025, CMS published updated guidance implementing the February 25 Executive Order 14221, “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information.”

Key updates include:

  • Hospitals must discontinue encoding “999999999” in the estimated allowed amount field and instead provide an actual dollar value.
  • Estimated amounts must be derived from the past 12 months of 835 remittance data (when available), or populated using a reasonable expected reimbursement (when claims transactions are unavailable).

What’s New as of May 22, 2025

On May 22, 2025, CMS published updated guidance implementing the February 25 Executive Order 14221, “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information.”

Key updates include:

  • Hospitals must discontinue encoding “999999999” in the estimated allowed amount field and instead provide an actual dollar value.
  • Estimated amounts must be derived from the past 12 months of 835 remittance data (when available), or populated using a reasonable expected reimbursement (when claims transactions are unavailable).

Real-World Enforcement: What CMS Is Flagging

While CMS doesn’t require “one click” by law, enforcement reviews are citing:

✅ Files that take 3+ clicks to access from the homepage

✅ Buried or unclear navigation

✅ Files that won’t open, crash, or require special tools to view

Best practice: Make your MRF reachable in 1–2 clicks, clearly labeled, and easily downloadable.

What You Get with the Hospital Price Index

Generate CMS-compliant files automatically
We take your claims and contract data and turn them into valid machine-readable and shoppable service files — no spreadsheet wrangling required.

Build a defensible pricing strategy
We translate complex payer contracts into clear rates that can be justified to CMS, payers, and patients.

Stay ahead of changing regulations
Our team tracks evolving CMS guidance so your files stay compliant without rework every time something shifts.

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See What HPI Can Do For Your Organization