On Friday, December 18, 2020, the Centers for Medicare & Medicaid Services (“CMS”) issued a special alert to remind hospitals that the Hospital Price Transparency final rule (“final rule”) requirements are effective starting January 1, 2021 and that CMS will monitor a “sample of hospitals” when the final rule goes into effect to determine compliance with its requirements.

CMS also reminds hospitals in this special alert that it has the authority to monitor hospitals by evaluating complaints, reviewing analyses of noncompliance, and/or by auditing hospitals’ websites. If a hospital remains noncompliant, CMS also states that it may take any of the following authority actions:

  • “Provide a written warning notice” of a hospital’s specific violations;
  • “Request a Corrective Action Plan” (“CAP”); and/or
  • Impose a civil monetary penalty of at least $300 per day of noncompliance.

The special alert also includes the following helpful links related to Hospital Price Transparency requirements: the Hospital Price Transparency website; FAQs; 8 Steps to a Machine-Readable File; 10 Steps to a Consumer-Friendly Display; and Hospital Price Transparency Requirements Quick Reference Checklists.