45 CFR Part 180 Every subsection, on every file — verified, not assumed

The most rigorous 45 CFR Part 180 compliance pack a hospital can deploy.

Hospital Price Transparency Compliance Engine assembles a documentation-complete compliance pack — every required data element, every schema validation, the percentile allowed amounts, and the attestation block — checked against the letter of 45 CFR Part 180 and the CMS data dictionary before a specialist releases it.

Every subsection of 45 CFR Part 180CMS schema-conformant MRF + shoppable displayMedian / 10th / 90th percentile allowed amountsSpecialist release on every packQuarterly re-validation SLA
Why compliance fails

A single missing data element can trigger a six-figure penalty.

Every licensed U.S. hospital must publish a machine-readable file of standard charges and a consumer-friendly display of shoppable services. Since July 2024, the MRF must conform to a rigid CMS template and data dictionary. And starting January 2026, hospitals must compute and include median, 10th, and 90th percentile allowed amounts from their own claims history.

Most hospitals cannot do this. Full compliance dropped from 34.5% to 21.1% in a single year. CMS has shifted from warnings to dollars, fining hospitals up to $309,738 per cycle. The new percentile requirement will push many currently-passing hospitals back into non-compliance.

Hospital Price Transparency Compliance Engine exists to close that gap with a single, exhaustive standard applied identically to every file.

21.1%
of hospitals fully compliant — and falling
The benchmark

Measured against the letter of the regulation — subsection by subsection.

We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of 45 CFR Part 180 and the CMS data dictionary. These are the provisions each pack is held to.

45 CFR 180.50(b)

Machine-readable file

All standard charges for all items and services in a CMS-schema-conformant JSON/CSV file, including payer-specific negotiated rates, discounted cash prices, and minimum/maximum negotiated rates.

45 CFR 180.60

Shoppable services display

A consumer-friendly list of at least 300 shoppable services with payer-specific negotiated rates, or a CMS-approved alternative.

45 CFR 180.70

Attestation

A signed attestation by an authorized hospital official certifying the accuracy and completeness of the data, re-validated quarterly.

CY2026 OPPS Final Rule

Percentile allowed amounts

Median, 10th, and 90th percentile allowed amounts computed from the hospital's own historical claims (835 remittance data), replacing estimated amounts.

CMS Data Dictionary v2.0

Schema validation

Every MRF passes the CMS Validator and conforms to the published data dictionary, including required fields, data types, and code sets.

45 CFR 180.90

Enforcement response

A documented response package for any CMS warning letter or request for information, prepared within the required timeframe.

How a pack is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human specialist signs every release. That order is never reversed.

01

Compliance Gap Scan

Upload the chargemaster, payer contracts, and 835 remittance data. We return a free completeness read: which data elements and schema requirements you already have, and which are missing.

02

Data ingestion & normalization

As your authorized clerical agent, we ingest and normalize the chargemaster, payer contracts, and 835 files into a structured data model, mapping codes and rates.

03

AI extraction & computation

AI extracts negotiated rates from contracts and computes median/10th/90th percentile allowed amounts from claims data. Results are cross-checked against source documents.

04

Deterministic completeness gates

Schema validation against CMS data dictionary, field-level completeness checks, percentile calculation verification, and attestation block accuracy. Any failure blocks release.

05

Specialist release

A revenue-integrity specialist reviews the exception queue and signs the release. High-complexity or high-penalty-risk files route to attorney review first.

06

Delivery & publication

You receive the MRF, shoppable display files, attestation block, and validation report — ready for the hospital to publish under its own name. Quarterly re-validation ensures ongoing compliance.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No pack ships without a human signature.
Operating commitment
Re-validation cycle
Every file re-checked against the latest CMS schema and rule updates.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
4
Data sources ingested
Chargemaster · payer contracts · 835 remits · CMS schema, every applicable file.
Why Hospital Price Transparency Compliance Engine

Built to be the most thorough option a hospital has.

Documentation-complete, by design

The deliverable is completeness itself — every data element and schema requirement accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run computations as your clerical agent. We never give legal advice, attest on your behalf, or interact with CMS directly.

Engagement

Flat fee, per facility per year. No contingency, ever.

Simple, predictable, and aligned with a compliance standard — not a percentage of any penalty avoided.

  • A free Compliance Gap Scan before you commit — see exactly what is missing.
  • One flat annual subscription per facility; disclosed pass-through data processing fees.
  • Optional fixed-fee attorney review for high-complexity or high-penalty-risk files.
  • Optional Enforcement Response Add-on for CMS warning letter preparation and submission.
FAQ

Questions, answered precisely.

Is Hospital Price Transparency Compliance Engine a law firm?
No. Hospital Price Transparency Compliance Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for high-complexity or high-penalty-risk files.
Do you interact with CMS or attest on our behalf?
Never. We prepare the MRF, shoppable display, and attestation block for your authorized official to review and sign. The hospital remains the responsible party for publication and attestation.
What makes a pack 'complete'?
Completeness is defined by the regulation: all required data elements present, schema validation passed, percentile amounts computed correctly, attestation block accurate, and all fields conforming to the CMS data dictionary. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is 10 business days from complete intake to a specialist-released pack. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat annual subscription per facility, plus disclosed pass-through data processing costs. No contingency and no percentage of any penalty avoided or recovery.

See what's missing before it costs you a penalty.

Start with a free Compliance Gap Scan. Send your chargemaster, payer contracts, and 835 remittance data and we'll return a completeness read against every subsection of 45 CFR Part 180.

Documentation-completeness service · not legal advice · the hospital publishes every file.