How We Determine Hospital Price Transparency Final Rule Adoption

It is important to note that Turquoise Health is not the government-appointed arbiter of price transparency compliance. Only The Centers for Medicare & Medicaid Services (CMS) can deem an organization compliant Turquoise Health is not the government-appointed arbiter of price transparency compliance. Only The Centers for Medicare & Medicaid Services (CMS) can deem an organization compliant with requirements. Our intention with reporting on final rule adoption is to share our non-biased findings and encourage adoption of these rules nationwide.

The  CY 2024 Hospital Outpatient Prospective Payment System (OPPS) Final Rule includes required schemas for hospital machine-readable files (MRFs) as of 1/1/24, 7/1/2024, and 1/1/25. From new data elements to schema and algorithms, the OPPS Final Rule criteria represent a new facet of what it means for a hospital to be “transparent” with its prices. 

Our Process

While we are confident in the process outlined below, we recognize that a margin for error does exist. Our only goal is to encourage the adoption of these standards nationwide.

If after reading you feel there’s been a miscalculation on our part, please do not hesitate to let us know at info@turquoise.health.

Download Schedule

If a hospital’s text file is available, Turquoise will check for a new machine-readable file once per week. If a new file is available, it will be downloaded and validated. We commit to downloading and validating all available hospital MRFs – even those without text files – at least once each fiscal quarter.

Price Transparency Text Files

This section outlines how we search for hospital price transparency text files – mandated by CMS as of 1/1/2024 – per the guidelines listed here.

Each night, we navigate to the website we have on file for every hospital. To see what website we have for a specific hospital, you can click on the hospital’s name in the MRF Tracker:

This will bring you to Turquoise’s page for this provider, which holds the Website URL:

In this case, our Website for Honor Health Deer Valley Medical Center is: https://www.honorhealth.com/locations/hospitals/deer-valley-medical-center?utm_source=GMB&utm_medium=local&utm_campaign=Valley_Medical_Center

We then strip the link for this hospital down to its root URL. In this case: www.honorhealth.com.

Next, we add the suffix “/cms-hpt.txt” to the root URL, in search of the required TXT file at its correct location per CMS. In this case, we’re left with www.honorhealth.com/cms-hpt.txt .

Finally, we ingest this data and map the locations displayed in the file to our database of hospitals. When we find a match, we give the hospital a ✅ indicating that their MRF Location File is present!

If we cannot find a text file for a given hospital, we will mark them on the MRF Tracker as “Not Found” and provide a link to where we are expecting to find their text file.

There are a few reasons this might be the case – check out the FAQ below for a complete rundown.

Adoption of CMS MRF Schema

This section outlines how we validate for adoption of CMS’s form and manner requirements (45 CFR 180.50(c)(2)) – effective 7/1/2024 – outlined here. 

This one’s simple – we’ve brought CMS’s Online Validator tool into our pipeline. If you upload a file to this page and it passes – it’ll pass ours too. We deem a “Pass” as any file that has no “Errors” in this tool. Any “Warnings” are not taken into account.

Every Sunday night, we programmatically go through the “MRF URL” from each price transparency text file, and see if a new file has been posted. If so, we will download that MRF.

The “Last Checked” and “Next Checked” dates of the MRF Tracker confirms the last time we ran this weekly review, and when the next one is scheduled:

Each time we download a new MRF from a hospital’s website, this validation is automatically and immediately run. The results of this validation feed directly into the Live MRF Tracker page.

If we have not yet found an MRF that adopts the CMS standard for a hospital, we will mark them as “Not Found”. There are a few reasons this might be the case – check out the FAQ below for a complete rundown.

If we have not found a text file for a hospital, finding newly posted MRFs is a little more difficult. This entails going to each hospital’s website, finding, and manually downloading their MRF. We commit to downloading all available hospital MRFs – even those without text files – at least once each quarter. 

To see the last time we successfully found a new MRF for a hospital, you can reference the “Last Downloaded” date of the Live MRF Tracker:

Occasionally we’ll be made aware of new MRFs in the middle of a week. Rather than wait until the weekend, we’ll download that data immediately! In those cases you may see that the “Last Downloaded” date is more recent than the “Last Checked”.

If you’re struggling to navigate hospital price transparency compliance, don’t hesitate to reach out with questions!

Live MRF Tracker – FAQ

I click on the “Not Found” link under “Text File” and I do see a text file listed at the web page. Why haven’t you marked this hospital’s text file with “Text File – Yes” yet?

1. Formatting: Our scripts are quite strict to the format listed at the CMS website here. If there are discrepancies in formatting, this can result in us being unable to correctly take in the data from the file. 

2. Blocked IP Address: Hospital or health system’s websites sometimes have software blocking our IP from ‘scraping’ their text file. If we’re not allowed access to the contents of the file, we can’t use them to find an MRF!

When we come across these cases, we will reach out to the contact-name listed in the text file. If you suspect this may be the case for your hospital, you may want to reach out to your organization’s IT team.

3. Timing: If the text file was added within the last week, we may just have not yet had the chance to ingest the file and map it to a provider in our database. This process typically takes about a week.

4. Provider naming: This one is rare – but hospitals sometimes change their names. It’s possible we have one name for a hospital, but a health system has them under a different name. This can affect our matching of a text file’s MRF to a hospital in our database. If you think this is the case, please reach out and let us know!

A hospital I know has an MRF that passes the CMS validator is marked as “V2 Schema – Not Found”. Why aren’t they marked with “V2 Schema – Yes”?

1. No text file: If we haven’t found a text file for a hospital, it’s much more difficult for us to check for new files on a recurring basis. In cases where a text file cannot yet be found, we will manually download the MRF for all hospitals at least once each quarter. 

2. Timing: If a new file was posted within the last week, it’s possible we may have just not yet had the chance to to ingest it and run it through the CMS Validator.

3. Two MRFs posted: We’ve found cases where a hospital has one v2 schema file posted on their website, but the text file points to an older, non-v2 MRF. If this is the case, our automated system will defer to ingesting the MRF it sees in the text file.

The MRF Tracker says my hospital’s file hasn’t been downloaded in over a week. Why is that?

1. No new file: If there’s no new file, we won’t bother ingesting it. If any aspect of the file – contents, size, etc. – changes from the last time we downloaded it, we will re-ingest it and re-run it through the CMS validator.

2. No text file: If we haven’t found a text file for a hospital, it’s much more difficult for us to check for new files on a recurring basis. In cases where a text file cannot yet be found, we will manually download the MRF for all hospitals at least once each quarter. 

How often does Turquoise look for new MRFs?

For all hospitals for which we have found a text file: Every Sunday evening we go to the MRF URL listed in that hospital’s text file, and check for a new MRF. If we find a new MRF, we will download it.

For all other hospitals: If we haven’t found a text file for a hospital, it’s much more difficult for us to check for new files on a recurring basis. In cases where a text file cannot yet be found, we will manually download the MRF for all hospitals at least once each quarter. If you have any questions, or believe we have incorrectly assessed your hospital, please reach out at info@turquoise.health.