Allowed amounts
4 fields
- Median, 10th and 90th percentile in dollars, plus count
- From 835 data, 12 to 15 month lookback; next highest observed value when between two amounts [4]
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The CY2027 price transparency RFI: what CMS asked about standardization
Short answer: the RFI in the CY2027 OPPS proposed rule asked how to standardize machine-readable file data, report outliers, stop-loss, tiering and carve-outs, and whether estimator deemed compliance should survive. Nothing changes yet. Read it as a list of fields CMS wishes it had.
CMS-1850-P · Jul 7, 2026Docket CMS-2026-23444 allowed-amount fields since Jan 1, 20260 requirements changed
Edition
Oct 2026
Focus
Price transparency
Audience
Compliance · Revenue integrity
Framework
CMS-1850-P
Effective date
None yet, RFI
Length
5 min read
How the RFI builds on the 2026 fields
- 1Jan 1, 2024CMS template, cms-hpt.txt and footer link required [3]
- 2Jan 1, 2026Allowed-amount fields, attestation, CEO name, Type 2 NPIs [4]
- 3Apr 1, 2026Enforcement of the 2026 fields begins
- 4Jul 7, 2026Standardization RFI published in CMS-1850-P [2]
- 5Aug 31, 2026RFI comments close [3]
- 6Nov 2026CY2027 final rule expected; any RFI outcome comes later
Required
Template, then allowed amounts and attestation
Asked, not required
Standardization, contract mechanisms, display
In forceRFI only
Five areas, and what each would mean as a rule
The contract mechanism question has operational weight: an outlier provision or a stop-loss threshold is not a single dollar charge, so today it is described in words. CMS is asking whether it should be data [2].
| Area | What CMS asked | If it became a rule |
|---|---|---|
| MRF standardization | Approaches to improve comparability and standardization of the information reported in machine-readable files | Tighter templates and fewer free-text escape hatches |
| Contract mechanisms | How to report outlier payments, stop-loss provisions, rate tiering and carve-outs | Structured fields for the parts of a contract that today sit in notes, or nowhere |
| Free-text accuracy | Improving the accuracy and completeness of free-text field reporting | Validation rules or controlled vocabularies for the notes fields |
| Consumer display | Enhancing the consumer-friendly display; whether to modify or eliminate deemed compliance for internet-based price estimator tools | Hospitals relying on an estimator might need a 300-service display |
| Shoppable services and displayed prices | Updating the required shoppable services list; clarifying which ancillary and bundled items a displayed price includes | A revised 70-service list and explicit bundling rules |
Allowed amounts, attestation, accountability, identity
The attestation's third part already requires the fee schedule or components behind a formula contract. The RFI asks whether those components should be structured fields.
Attestation
3 parts
- Complete and accurate as of the file date
- All dollar-expressible negotiated charges included
- Fee schedule or components supplied where a dollar amount is not knowable [4]
Accountability
Named official
- CEO, president or designated senior official named in the file [4]
Identity
Type 2 NPIs
- Primary taxonomy beginning 28 or 27, active at the last update [4]
Four desks, one inventory
RFI areas by owning desk (count of the five RFI areas each desk leads)
Preparation that pays off whether or not the RFI becomes a rule.
Managed carecontract mechanism inventory: outliers, stop-loss, tiers, carve-outs by payer
1 areacontract mechanisms
Revenue integrityfree-text review and attestation evidence
2 areasMRF standardization, free-text accuracy
Patient accessestimator test and shoppable services display
2 areasconsumer display, shoppable services
Compliancenamed official sign-off and enforcement playbook
all 5signs off every area
Contract dataFile dataDisplaySign-off
Takeaway
Read the RFI as a list of fields CMS wishes it had. The hospitals that can already produce them will have the easiest 2028.
Five preparations, block G of the MRF self-audit
Inventory contract mechanismsFor each payer contract, list outlier provisions, stop-loss thresholds, rate tiers and carve-outs, with the contract section that defines each.
Review every free-text fieldCompare each note in the current MRF to the contract it describes; rewrite the ones a stranger could not follow.
Test the estimator against a displayIf you rely on a price estimator, know what it would take to post a 300-service display within one update cycle.
Document what displayed prices includeFor each shoppable service, record which ancillary and bundled items the displayed price covers.
Re-run the 2026 auditThe allowed-amount recomputation and attestation review in our MRF audit checklist are the foundation; our hospital billing and revenue integrity teams run it from the command center where contract terms are already modeled.
Know what the RFI does not doNo requirement changes for 2026 or 2027, no date, no change to monthly reviews and penalties (see the 2026 enforcement brief). Read with this month's Hospital Cash Cycle and the prior authorization expansion; our hospital revenue cycle team will walk your revenue integrity lead through the inventory.
Frequently asked questions
Did the CY2027 OPPS proposed rule change hospital price transparency requirements?
No. It contains a request for information on strengthening the standardization and comparability of price transparency data. Any change to the requirements would come through a future proposed rule.
What did the RFI ask about?
Standardizing machine-readable file data, reporting contract mechanisms such as outlier payments, stop-loss provisions, rate tiering and carve-outs, improving free-text field accuracy, whether to modify or eliminate deemed compliance for internet-based price estimator tools, updating the shoppable services list, and clarifying which ancillary and bundled items displayed prices include.
When did comments close?
August 31, 2026 at 11:59 PM EDT, on docket CMS-2026-2344.
What should a hospital do about the RFI now?
Inventory contract mechanisms by payer, review every free-text field in the current file against the contract, know whether you could post a 300-service display if estimator deemed compliance ended, and keep the 2026 allowed-amount and attestation audit current.
- CMS fact sheet: CY 2027 Hospital OPPS and ASC Payment System Proposed Rule (CMS-1850-P), July 2, 2026
- Federal Register: CY 2027 OPPS and ASC proposed rule (CMS-1850-P), 91 FR 41733, July 7, 2026
- CMS: Hospital Price Transparency (key initiatives page, updated September 16, 2026)
- CMS fact sheet: CY 2026 OPPS/ASC Final Rule, Hospital Price Transparency Policy Changes (CMS-1834-FC, November 21, 2025)
Preparation that pays off whether or not the RFI becomes a rule.
Want the contract mechanism inventory built for you?
We read your payer contracts for outliers, stop-loss, tiering and carve-outs, compare them to the free-text fields in your current file, and hand revenue integrity a worksheet that answers the RFI and the attestation at once.