Hospital price transparency is often treated as a finance or compliance project, but most of the rule is about a website. The files have to be posted online, linked from a specific place, readable by machines and people, and kept current. When a hospital redesigns its site, moves to a new content management system or changes web vendors, these pieces are easy to lose, and CMS checks them.
This guide is for hospital marketing and web teams and the agencies that work with them. It explains what 45 CFR Part 180 requires a hospital website to show, how CMS enforces it, and how it differs from the good faith estimate and No Surprises Act rules that also apply to many hospitals and practices. For price tools on practice websites, which this rule does not cover, see our guide to cost estimator tools on a practice website. For the notice Medicare patients get about two charges, see facility fee disclosure.
This is general information, not legal advice. Sources cited were checked on October 29, 2026: 45 CFR 180.10, 180.20, 180.30, 180.40, 180.50, 180.60, 180.70, 180.80 and 180.90 (Hospital Price Transparency, as amended through 90 FR 54087, November 25, 2025) and the CMS Hospital Price Transparency page. CMS updates these requirements through its annual outpatient payment rules, so check the CMS page for changes after that date. Have a health care attorney and your compliance team review your price transparency pages.
Who the rule applies to
45 CFR Part 180 implements section 2718(e) of the Public Health Service Act, which requires each hospital operating in the United States to make public a list of its standard charges each year. Under 45 CFR 180.20, a hospital is an institution licensed as a hospital under state or local law, or approved by the licensing agency as meeting the standards for licensing.
45 CFR 180.30 deems federally owned hospitals (including Veterans Affairs and military treatment facilities), hospitals operated by an Indian Health Program, and state forensic hospitals that treat only people in the custody of penal authorities to be in compliance. If your organization is a physician practice or a facility that is not licensed as a hospital, Part 180 does not apply to it as written, but other price disclosure rules may, as explained below.
The two things a hospital must post
45 CFR 180.40 says a hospital must make public two things:
- A machine-readable file containing a list of all standard charges for all items and services, under 180.50.
- A consumer-friendly list of standard charges for a limited set of shoppable services, under 180.60, or a price estimator tool that meets the rule’s conditions.
Under 180.20, a standard charge is the regular rate the hospital has established for an item or service provided to a specific group of paying patients. The rule names five types: the gross charge, the discounted cash price, the payer-specific negotiated charge, and the de-identified minimum and maximum negotiated charges. A shoppable service is one a patient can schedule in advance.
The machine-readable file: what the website has to do
Most of 180.50 is about the data in the file, which your finance and revenue cycle teams produce. Several parts are about where and how the file is published, and those usually fall to the web team. Under 180.50(d) and (c):
- The file must be posted on a publicly available website, displayed in a prominent manner and clearly identified with the hospital location it applies to.
- It must be free, and available without creating an account or password and without submitting personal identifying information.
- It must be accessible to automated searches and direct file downloads through a link posted on a publicly available website. Blocking crawlers or putting the file behind a form or a script that bots cannot follow works against this.
- The file and its contents must be digitally searchable, and since July 1, 2024 the file must follow the CMS template layout, data specifications and data dictionary.
- The file name must follow the CMS naming convention: the hospital EIN, then the hospital name, then standardcharges, as a json or csv file.
- Since January 1, 2024, the website hosting the file must keep a .txt file in its root folder listing the hospital location name, the source page URL, a direct link to the file and a point of contact.
- The website must have a link in the footer, including on the homepage, labeled Price Transparency, that goes directly to the page hosting the link to the file.
Each hospital location under a single license that has a different set of standard charges must publish its own charges, under 180.50(a)(2). Under 180.50(e), the information must be updated at least once a year, and the file must show the date of the most recent update. Beginning January 1, 2026, 180.50(a)(3)(iii) also requires the file to contain a specific attestation that the information is true, accurate and complete to the best of the hospital’s knowledge and belief.
Shoppable services or a price estimator
Under 180.60(a)(1), a hospital must show standard charges for as many of the 70 CMS-specified shoppable services as it provides, plus enough hospital-selected shoppable services for a combined total of at least 300. If it provides fewer than 300, it shows as many as it provides. Each one needs a plain-language description, the charges listed in the rule, the location and setting, and the billing code.
The hospital chooses the format for this display under 180.60(c), but 180.60(d) requires it to be prominent, identified with the hospital location, free, available without an account or personal information, and searchable by service description, billing code and payer. It must be updated at least once a year with the date of the last update clearly shown.
Alternatively, under 180.60(a)(2), a hospital is deemed to meet these requirements if it maintains an internet-based price estimator tool that covers the same 300 services, lets patients get an estimate of what they will owe at the time they use it, and is prominently displayed on the website and free to use without registering or creating an account or password.
How CMS enforces the rule
Under 45 CFR 180.70, CMS may monitor compliance through complaints, review of outside analyses, audits, and requests for certification or documentation. If it finds a hospital noncompliant, it may, generally in this order, send a written warning, request a corrective action plan under 180.80, and impose a civil monetary penalty under 180.90 if the hospital does not respond to the request or does not follow the plan. CMS may publicize its assessments, compliance actions and penalties on its website.
As written in 180.90(c), the maximum daily penalty since 2022 depends on the hospital’s bed count: 300 dollars for 30 beds or fewer, 10 dollars per bed for 31 to 550 beds, and 5,500 dollars for more than 550 beds. The CMS Hospital Price Transparency page links to a list of hospitals that have been issued penalties. It also says CMS began enforcing the requirements finalized in the CY 2026 outpatient payment rule on April 1, 2026, and that the CY 2027 proposed rule included a request for information on making hospital price data more standardized and comparable.
A website checklist for hospital marketing teams
These are the points we would check on any hospital website, especially before and after a redesign or migration:
- The footer link. A link labeled Price Transparency appears in the footer of every page template, including the homepage, and goes directly to the page that hosts the file link.
- The txt file. The root .txt file still exists after the migration and points to the current page and file URLs.
- The file URL. The file is still at the URL the txt file and the page link to, uses the CMS naming convention, and downloads without a login, a form or a cookie banner that blocks it.
- Robots and security rules. Robots rules, firewall settings and bot protection do not block automated access to the page, the txt file or the file.
- Each location. Every location with its own charges has its own clearly labeled file and display.
- The shoppable services page or estimator. It is linked from the price transparency page, searchable by description, code and payer, and shows the date it was last updated.
- Accessibility. The pages work with a keyboard and screen readers, since patients use them too; see our guide to website accessibility for medical practices.
- Tracking. Price and estimator pages can reveal what care someone is considering. Review which analytics and advertising tags run on them; see our guide to tracking pixels on practice websites.
Write down who owns each piece: finance owns the data, the web team owns the links and files, and compliance signs off. When we build or rebuild a site through our medical website design service, we treat these links and files as required parts of the launch checklist.
How this differs from good faith estimates and No Surprises Act notices
Hospital price transparency is one of several price disclosure rules, and they are easy to mix up. Part 180 is about publishing standard charges for everyone to see. Good faith estimates are individual estimates given to uninsured or self-pay patients when they schedule care or ask about cost; see our guide to good faith estimates for self-pay patients. The No Surprises Act also requires covered providers and facilities to post a disclosure about patient protections against balance billing; see our guide to No Surprises Act website disclosure.
A hospital may need to meet all three, and each has its own content, place and timing. Keep them on clearly labeled pages rather than combining them into one notice.
Using prices in marketing
Some hospitals advertise cash prices for shoppable services such as imaging or lab work. If you do, the advertised price should match what the hospital has posted as its discounted cash price for that service and location, and the ad should say what is included and what is not. A price in an ad that differs from the hospital’s own posted file invites complaints and confusion. Have the finance team confirm prices before any campaign launches, and update ads when the annual file changes.
If a hospital pharmacy or clinic promotes a prescription discount card next to its prices, the card copy brings its own questions: not insurance wording, savings claims, Medicare and payments from the card company. See our guide to prescription discount card marketing.
Does the hospital price transparency rule apply to physician practices?
45 CFR Part 180 applies to hospitals as defined in 180.20, meaning institutions licensed or approved as hospitals under state or local law. A practice that is not a hospital is not covered by Part 180 as written, but it may have good faith estimate and No Surprises Act obligations.
Where does the Price Transparency link have to go?
Under 45 CFR 180.50(d)(6)(ii), in the website footer, including on the homepage, labeled Price Transparency, linking directly to the page that hosts the link to the machine-readable file.
How often must the files be updated?
At least once a year under 180.50(e) and 180.60(e), with the date of the most recent update shown.
Can we require patients to enter an email to use our price estimator?
No. Under 180.60(a)(2)(iii), a price estimator used to meet the shoppable services requirement must be accessible without charge and without registering or creating an account or password, and 180.60(d)(3) bars requiring personal identifying information for the shoppable services display.
What happens if CMS finds a problem?
Under 180.70, CMS generally sends a warning first, then may request a corrective action plan, and may impose a civil monetary penalty under 180.90 if the hospital does not respond to or follow the plan. CMS may publish its actions on its website.
Sources
- 45 CFR 180.10: Basis and scope
- 45 CFR 180.20: Definitions
- 45 CFR 180.30: Applicability
- 45 CFR 180.40: General requirements
- 45 CFR 180.50: Requirements for making public hospital standard charges for all items and services
- 45 CFR 180.60: Requirements for displaying shoppable services in a consumer-friendly manner
- 45 CFR 180.70: Monitoring and enforcement
- 45 CFR 180.80: Corrective action plans
- 45 CFR 180.90: Civil monetary penalties
- CMS: Hospital Price Transparency