Price Transparency

Wisconsin hospitals and health systems are committed to empowering patients with access to accurate and timely pricing information so they can make informed decisions when seeking care. Significant investments have been made in technology and staffing to adopt federal hospital price transparency requirements, which includes posting “machine-readable files” and shoppable services lists. To make all this consumer friendly, though, more and more hospitals have also invested in price estimator tools that allow anyone to get a price estimate for a variety of services.

Not one Wisconsin hospital or health system has been fined by the federal government for non-compliance with the law. However, groups outside of Wisconsin want you to think otherwise. It's time to set the record straight.


The Truth on Transparency

Hospital price transparency requirements are already in place and are being enforced at the federal level. Creating a new set of state-level requirements will only add unnecessary cost and administrative burden to Wisconsin hospitals.

Wisconsin hospitals are complying with hospital price transparency laws, but they are only one part of the health care cost equation. What about insurance companies? Out-of-state health insurers are profiting more than ever while premiums for families and businesses continue to rise. Instead of owning up, they point the finger at Wisconsin's nonprofit hospitals.



Get the Facts

Myth #1: "Hospitals can’t just pay their fines and walk away", Quote from Senator Mary Felzkowski, the Lakeland Times, Nov. 8, 2022.

Fact: Not one Wisconsin hospital has been fined by the federal government for noncompliance. Quite the opposite – third parties are downloading files from Wisconsin hospitals and giving them high marks for completeness.

Myth #2: CMS has failed to hold noncompliant hospitals accountable.

Fact: CMS has initiated compliance actions with over 2,700 hospitals across the country and continues issuing new rules related to monitoring and enforcement.

Myth #3: Senate Bill 328 will lower health care costs.

Fact: The growing portion of health care costs in the United States relates to “middlemen” in the health care system, not the actual doctors, nurses and hospitals delivering care. These middlemen now comprise over 40% of overall health care spending in the United States. Senate Bill 328 doesn’t apply to the middlemen.

Myth #4: Only 36% of hospitals in the country are compliant with the federal requirements.

Fact: The American Hospital Association says the report that includes this statement “blatantly misconstrues, ignores, and mischaracterizes hospitals’ compliance with federal price transparency regulations.” CMS says the number of compliance hospitals is much higher. And CMS is the only true arbiter of compliance. They have sent warning letters directly to hospitals in Wisconsin, and those hospitals have resolved any issues to the satisfaction of CMS.

Myth #5: If hospitals are complying with the existing federal rule then there should be no cause for concern with layering on state regulations through Senate Bill 328.

Fact: SB 328 contained at least 18 differences from the federal rules when it was introduced in June, and as CMS finalized new rules in November 2023, SB 328 is even more obsolete today. SB 328 is unnecessary and will only serve to increase compliance costs.

Myth #6: Health insurers and businesses are publishing files and providing their employees with price estimator tools as required by the federal law.

Fact: Enforcement of the rules for insurers and self-funded plans is lacking. While the federal government is definitely enforcing compliance on hospitals, there is no similar data available at any level of government about insurer, employer or TPA compliance or enforcement.

WHA Testimony in Opposition to Senate Bill 328 WHA Response to Patient Rights Advocates False Claims WHA Memo to the Wisconsin State Legislature 6/5/2025

2025 CMS Hospital Price Transparency Resources

Hospitals across the country will soon face updates to federal price transparency requirements. Under the CY 2026 Hospital Outpatient Prospective Payment System (OPPS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) are introducing new standards designed to make pricing data more consistent, comparable and useful for patients and payers. These changes take effect January 1, 2026, with enforcement beginning April 1, 2026.

The rule expands what hospitals must disclose in their machine-readable files (MRFs). In addition to standard charges and payer-specific negotiated rates, hospitals will now be required to include percentile-based allowed amount data elements whenever negotiated charges are based on percentages or algorithms. Specifically, hospitals must report the median allowed amount, the 10th and 90th percentile allowed amounts, and the count of allowed amounts used in calculations. These figures must be derived from electronic remittance advice (ERA) data or an equivalent source, ensuring accuracy and uniformity nationwide. CMS has also strengthened attestation requirements, requiring a senior official, such as a CEO, to certify the completeness and accuracy of posted data.


CMS Webinar Recordings


To support compliance, we've provided the following links to essential resources and tools from the American Hospital Association (AHA) and CMS. 


American Hospital Association Resources

The AHA provides tools, FAQs and best practices specifically designed to assist hospitals with understanding and implementing price transparency measures.

AHA Price Transparency Resources


CMS Final Rule

Access the official 2026 CMS Final Rule on the Federal Register website for detailed information on the new requirements.

CMS Final Rule on Hospital Price Transparency

CMS Hospital Price Transparency Resources

Explore a comprehensive set of resources, including fact sheets and educational materials, to support your facility’s compliance efforts.

CMS Hospital Price Transparency Resources

Data Dictionary

Review the CMS Data Dictionary to understand the standardized data elements and formats for hospital price transparency.

CMS Hospital Price Transparency Data Dictionary

Transparency Tools

Use CMS’s transparency tools to help create, test and validate machine-readable files that comply with requirements.

CMS Transparency Tools

File Validator

Verify your facility’s machine-readable files for accuracy and compliance with CMS standards using the online validator tool.

CMS File Validator


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Resources