TQU

Hospital MRF Requirements

MRF Requirement 1: Effective 1/1/2021

Per the Hospital Price Transparency Rule, hospitals must publish a machine-readable file (MRF) to the hospital website in an easy-to-find location that is free to access. Within a healthcare system, each individual hospital must have its own individual MRF. The MRF must be updated annually and must report five types of standard charges:

  • Gross Charge: Rate for an individual item or service reflected in the hospital’s chargemaster (i.e. list price) 
  • Discounted Cash Price: Rate for an item or service administered by the hospital to a patient who will pay in cash or a cash equivalent
  • Payer-Specific Negotiated Charge: Rate negotiated with a third-party payer for an item or service
  • De-Identified Minimum Negotiated Charge: Lowest rate a hospital has negotiated with all third-party payers for an item or service
  • De-Identified Maximum Negotiated Charge: Highest rate a hospital has negotiated with all third-party payers for an item or service

The report must also include charge descriptions, any code used for billing (CPT, DRG, NDC, and other common identifiers), and revenue code. Hospitals that directly employ professionals must also disclose professional fees. Supplies, implantable devices, and pharmaceuticals must be included. 

In addition to individual items and services, service packages are also required. Service packages can be thought of as contract rate types, such as per diems, DRG case rates, or CPT per unit rates. For example, hospitals reporting a negotiated charge of $5,000 for CPT code 92928 must specify that the $5,000 is a per-unit rate.

Exclusions:

  • Government reimbursement rates (Medicaid, Medicare, Tricare) are excluded as they are already publicly available
  • Federally-owned hospitals (e.g. Veteran Affairs hospitals, hospitals operated by the Indian Health Program, or U.S. Department of Defense hospitals)
  • Freestanding ambulatory centers (ASCs, imaging centers, labs, etc.)

MRF Requirement 2: Effective 7/1/2024

In November 2023, CMS published the CY 2024 Hospital Outpatient Prospective Payment System (OPPS) Final Rule that included required schemas for hospital MRFs as of 7/1/2024. CMS finalized this rule after an open comment period that resulted in feedback submissions from stakeholders all across the industry and patients as consumers.

As compared to the Proposed Rule, the Final Rule extends the grace period for the new required schemas, which will go into effect on 7/1/2024.