Price Transparency

WINTERGREEN / FINANCIAL ADVISORY SERVICES

Price Transparency Compliance

Publish complete prices. Confirm they are accurate. Give patients clear estimates.

Every hospital must publish its standard charges, and since April 2026 CMS enforces actual allowed amounts and an attestation of accuracy. Clinics and other providers owe uninsured and self-pay patients a good faith estimate. We help rural hospitals and clinics build price transparency programs that are complete, accurate, and consistent with what patients are actually charged.

OUR FOCUS
01

Hospital Price Files

Machine-readable files built from reconciled charge, contract, and remittance data.

02

Consumer Pricing & Estimates

Shoppable services, price estimator tools, and good faith estimates for self-pay patients.

03

Attestation & Ongoing Compliance

Validation before each posting, clear ownership, and timely responses to CMS notices.

The Compliance Challenge

Published Prices Must Match What Patients Are Charged.

Price transparency is no longer a one-time posting. Hospitals must now publish median, 10th, and 90th percentile allowed amounts drawn from remittance data, list their Type 2 NPIs, and name the senior official who attests that the file is accurate and complete.

Wintergreen helps hospitals and clinics answer the core question: are the prices you publish complete, accurate, and consistent with what patients actually pay? From there, we build the data, ownership, and controls that keep each posting compliant.

What We Help Solve

Is Your Price Transparency Program Ready for Review?

  • Does your machine-readable file include every required element, including the new allowed amounts?
  • Are the chargemaster, payer contracts, and remittance data reconciled before each posting?
  • Who is named in the file, and how is accuracy confirmed before they attest?
  • Can patients easily find your shoppable services list or price estimator tool?
  • Are uninsured and self-pay patients offered a good faith estimate on time?
What’s at Stake

Penalties Scale with Hospital Size.

Exposure = Daily penalty × Days out of compliance

CMS usually sends a warning notice, then requires a corrective action plan within 45 days. A hospital that has posted nothing gets no warning. Penalties follow a missed plan or deadline, accrue every day until the problem is fixed, and are posted on the CMS website.

30 beds or fewer Up to $342 a day

About $125,000 for a full year out of compliance.

31–550 beds Scaled per bed, per day

Exposure grows with bed count between the two limits.

Over 550 beds Up to $6,277 a day

About $2.3 million for a full year out of compliance.

Maximums as adjusted for inflation in January 2026. Waiving a hearing within 30 days cuts a penalty by 35%, but only once, and the hospital gives up its appeal of later penalties for the same violation.

The Requirements

What Each Requirement Covers

Requirement Who and What
Machine-readable file All hospitals, including CAHs: gross, cash, payer, and min/max charges.
Allowed amounts Median, 10th, and 90th percentiles from remittance data when rates are a percentage or formula.
Attestation and NPI Senior official named in the file; Type 2 NPIs listed.
Shoppable services 300 services in plain language, or a price estimator tool.
Good faith estimates All providers and facilities, for uninsured and self-pay patients.
Insured estimates Advanced EOB rules are not yet final.
The Compliance Framework

Six Steps to Compliance.

A dependable price transparency program moves through the same sequence before every posting, from clear ownership to ongoing monitoring.

01

Ownership

A senior official and a team from finance, revenue cycle, compliance, and IT.

02

Source Data

Chargemaster, payer contracts, and 835 remittance data reconciled before posting.

03

Machine-Readable File

CMS template, every required element, with a footer link and .txt file pointing to it.

04

Attestation

Accuracy and completeness checked before each posting, because the official named in the file attests to it.

05

Consumer Display

Shoppable list or estimator tool, free and easy to find, with no login.

06

Estimates & Monitoring

Good faith estimates on time; CMS notices answered by their deadlines.

Building the Program

Five Ways to Build the Program.

Practical habits that keep published prices current, accurate, and useful to patients and to your own contracting team.

A

Update Calendar

Refresh the file at least annually and after every contract change.

B

Contract Inventory

Every payer contract and rate method mapped to file entries.

C

Validation

Run the CMS validator tool before each posting. A clean result confirms format, not accuracy.

D

Front-Desk Scripts

Staff offer estimates at scheduling and answer price questions.

E

Market Insight

Compare your rates with competitor and payer files before negotiating.

Common Pitfalls

What We See Most Often

  1. File posted once and never updated.
  2. Rates shown as percentages with no way to derive dollars.
  3. Price tool hard to find or behind a login.
  4. Self-pay patients not offered a good faith estimate.
The Wintergreen Approach

From Price File Review to Sustained Compliance

We treat price transparency as a standing program, not a one-time posting. CMS’s July 2026 request for input signals more standardization ahead.

STEP 01

Assess

Review your current price file, shoppable services display, and good faith estimate process against every requirement.

STEP 02

Reconcile

Match the file to the chargemaster, payer contracts, and remittance data, including the new allowed amounts.

STEP 03

Assign

Confirm who attests, define team roles, and set an update calendar tied to contract changes.

STEP 04

Validate

Test each posting with the CMS validator, check accuracy separately, and monitor for CMS notices.

The Value We Deliver

Accurate Prices. Confident Compliance.

A well-run price transparency program protects the organization from penalties, builds patient trust, and gives leadership a clearer view of how its rates compare in the market.

Reduced Penalty Risk

Complete, attested files and timely responses to CMS notices that avoid daily penalties.

Greater Patient Trust

Easy-to-find prices and good faith estimates that help patients plan for the cost of care.

Stronger Negotiating Position

Market rate comparisons that inform payer contract negotiations.

Sources: 45 CFR Part 180; CY 2026 OPPS/ASC final rule (CMS-1834-FC); 45 CFR 149.610 (good faith estimates); 45 CFR Part 102 (2026 penalty inflation adjustment). Current as of November 2026. Examples illustrative.

CONNECT WITH WINTERGREEN

Are Your Published Prices Ready for Review?

Incomplete files, unverified data, and missed estimates expose hospitals and clinics to penalties and erode patient trust.

Connect with Wintergreen to talk through price transparency at your hospital or clinic, from reconciling your price file to building the controls that keep every posting accurate.

Rob Bloom, Wintergreen Principal
YOUR POINT OF CONTACT

Rob Bloom

Principal | Wintergreen

View Professional Profile →
190 U.S. Route 1, Ste 215, Falmouth, ME 04105 info@wintergreenme.com 207.280.6495