The MRF Enforcement Window Is Closing — April 1, 2026 Is Not a Soft Deadline

CMS is now conducting over 200 comprehensive hospital compliance reviews per month — up from 30–40. The April 1, 2026 enforcement date applies to every hospital in the country.

Section 1: What Changed and When

On November 21, 2025, CMS published the CY 2026 OPPS and Ambulatory Surgical Center Final Rule, which includes significant changes to hospital price transparency regulations. The new requirements become effective January 1, 2026, with enforcement delayed until April 1, 2026.

The three-month window between effective date and enforcement date is not discretionary buffer — it is a compliance preparation period. Hospitals that miss April 1 without compliant files face immediate exposure to the enforcement process.

Section 2: What Hospitals Must Now Include

Four new requirements under the 2026 rule:

1. Median allowed amount — replacing estimated allowed amounts, based on actual claims data
2. 10th and 90th percentile allowed amounts — using EDI 835 remittance data from a 12–15 month lookback period
3. CEO/senior official attestation — named individual must certify accuracy and completeness
4. Type 2 NPI encoding — organizational provider identifier to enable cross-dataset matching with Transparency in Coverage files

The MRFs must meet several new requirements, some of which require diving into claims payment data. CMS is also updating its monitoring and enforcement process as part of an ongoing increase in government oversight of hospital price transparency compliance.

Section 3: The Enforcement Reality

The average time to complete a CMS enforcement case cycle is 195 to 220 days. Under the current enforcement process, the cycle begins with a warning notice allowing 90 days for correction, followed by a corrective action plan request with a 45-day deadline, then a compliance completion date of 30–90 days.

Of reviewed hospitals, 65% have received at least one warning notice or corrective action plan request. CMS has issued nine new civil monetary penalties in under six months under the current administration — compared to 18 issued over the entire prior administration.

The enforcement pace is accelerating. The 195-day average case cycle means that hospitals reviewed in April 2026 could face CMPs before the end of the calendar year.

Section 4: The Penalty Structure

• $10/bed/day, minimum $300/day
• Maximum $5,500/day ($2,007,500/year) for large hospitals
• A 35% CMP reduction is available for hospitals that waive their right to an ALJ hearing within 30 calendar days — but this reduction is unavailable if the violation is for failing to post an MRF or any shoppable services entirely, as these are considered “core” requirements.

Section 5: Compliance Checklist

Hospitals should verify before April 1:

• [ ] MRF includes median allowed amounts derived from 12–15 month claims lookback
• [ ] 10th and 90th percentile figures are encoded for all payer-specific rates based on algorithms or percentages
• [ ] Count of allowed amounts included per rate
• [ ] CEO or designated senior official name encoded in attestation field
• [ ] Attestation statement meets updated 45 CFR § 180.50 language precisely
• [ ] Type 2 NPI(s) encoded for all hospital locations
• [ ] TXT file in website root directory with MRF location and contact info
• [ ] File validated against CMS’s published MRF validator tool

Search your hospital’s published pricing data on HealthFees.org to see what’s currently visible to employers and patients — then compare to the new requirements.