45 CFR Part 180 Explained: A deep dive into the specific law governing Price Transparency.

45 CFR Part 180 Explained: What Hospital CFOs Actually Need to Know about the CMS Hospital Price Transparency Rule.

“Price transparency is no longer a publishing exercise. It is a pricing truth test.”

45 CFR Part 180 is the federal regulation that governs Hospital Price Transparency. In plain terms, it requires hospitals to publicly disclose what they actually charge and what they actually get paid, not what their chargemaster says in theory. CMS enforcement has matured. Hospitals that treat this as a compliance checkbox are now facing penalties, corrective action plans, and reputational exposure.

This regulation matters because it cuts across finance, revenue cycle, contracting, IT, and compliance—and failures tend to show up at the seams.

What the Law Actually Requires (Not What People Assume)

At the core of Part 180 is the definition of “Standard Charges.” CMS defines this precisely, and all five must be disclosed.

Required Standard Charge	What It Really Means	CFO Reality Check
Gross Charge	Chargemaster sticker price	Required, but not trusted
Discounted Cash Price	True self-pay price	Must be actionable, not “call billing”
Payer-Specific Negotiated Charge	Contracted rate per payer & plan	This is the hardest—and most scrutinized
De-identified Minimum	Lowest negotiated rate	Signals pricing spread risk
De-identified Maximum	Highest negotiated rate	Exposes contract outliers

“If one of the five prices is missing, CMS considers the entire disclosure incomplete.”

Two Public Outputs Are Mandatory

Hospitals must publish both of the following, continuously and without friction.

Output	Scope	Common Failure Mode
Machine-Readable File (MRF)	All items & services	Files that are unreadable, incomplete, or formula-based
Shoppable Services Display	≥300 services	PDFs, broken links, or vague descriptions

CMS does not care if the file exists. CMS cares if it is usable.

What the Regulation Explicitly Prohibits

CMS has been unusually direct about what does not qualify as compliance.

Prohibited Practice	Why CMS Rejects It
“Prices available upon request”	Not transparent
Percent-of-charges formulas	Not a price
Averaged or blended rates	Obscures payer reality
PDFs masquerading as data	Not machine-readable
Contract logic instead of numbers	CMS audits outputs, not intent

“If a data scientist cannot parse it, CMS does not consider it disclosed.”

Why Chargemasters Fail as a Compliance Backbone

Chargemasters were never designed to satisfy Part 180. They are billing catalogs, not pricing truth engines.

CDM Limitation	Impact on Compliance
No adjudication logic	Prices don’t match reality
Missing bundling rules	Overstates line-item prices
Inconsistent units	Inflates or deflates totals
Detached from contracts	Negotiated rates misrepresented

“Chargemasters describe intent. Claims data describes reality. CMS is auditing reality.”

Where CFOs Are Now Personally Exposed

CMS enforcement has moved from warnings to measurable consequences.

Enforcement Mechanism	Financial / Reputational Risk
Civil Monetary Penalties	Up to $5,500 per day
Public noncompliance lists	Board-level embarrassment
Corrective Action Plans	Forced rework + validation
Follow-up audits	Repeat exposure

This is no longer theoretical. CMS is sampling hospitals, not just reacting to complaints.

The Strategic CFO Takeaway

45 CFR Part 180 is not about transparency theater. It is about whether your hospital can defend its prices with evidence.

CFO Question	Modern Answer
“Did we publish a file?”	Irrelevant
“Do prices reconcile to claims?”	Critical
“Can we explain payer spreads?”	Mandatory
“Would this survive an audit?”	The only test

“Price transparency is now a finance function with regulatory consequences, not a web publishing task.”

Bottom Line

Hospitals that win under 45 CFR Part 180 do three things well:

1. They treat claims data as the source of truth

2. They reconcile chargemasters to adjudicated reality

3. They assume every published price will be audited

Those that don’t are discovering—expensively—that technical compliance and material compliance are no longer the same thing.

Next step: CMS Audit Checklist