HFMA Comments on CMS Hospital Price Transparency Accuracy and Completeness RFI

In a July 21, 2025, letter to CMS, HFMA submitted recommendations pertaining to the agency’s Request for Information (RFI) regarding the accuracy and completeness of hospitals’ machine-readable files. HFMA is a professional organization of more than 135,000 individuals involved in various aspects of healthcare financial management. HFMA is committed to helping its members improve the management of and compliance with the numerous rules and regulations that govern the industry. HFMA values the agency’s commitment to advancing price transparency. HFMA and our members are dedicated to supporting improved and meaningful transparency efforts and are eager to collaborate with CMS and other stakeholders to ensure consumers, patients, employers and all stakeholders receive clear financial information to prepare for healthcare items and services. We believe the fundamental goal of any price transparency policy should be to empower patients with healthcare cost information that is accurate, timely, and easy to understand. HFMA also supports expanding transparency efforts to better inform employers and other purchasers of employer-sponsored coverage. However, HFMA and our members are concerned that the continued focus on hospital charge master data and privately negotiated rates between providers and payers has overshadowed the development and promotion of more patient-, employer-, and care-centric tools that offer a more accurate reflection of real-world healthcare costs and enhance decision-making for all stakeholders. Furthermore, the growing patchwork of price transparency mandates at both the state and federal levels is generating confusion, administrative burden, and operational friction—rather than delivering clarity. A fragmented approach risks misalignment among key stakeholders across the healthcare ecosystem. HFMA urges CMS to focus on streamlining and aligning policies to ensure that compliance efforts enhance—rather than hinder—accessibility, accuracy, and the delivery of care.

In the letter, HFMA’s specific comments in response to the RFI include the following:

• Accuracy and Completeness of Machine-Readable File Data
• Policy Considerations to Improve Estimate Accuracy
• Need for Balanced Oversight Across Transparency Requirements