PRA and Tech Consortium Submit Recommendations to CMS RIF

PatientRightsAdvocate.org and several tech companies submitted their recommendations to the Centers for Medicare & Medicaid Services in response to the Request for Information on the accuracy and completeness of Hospital Price Transparency data.

In a letter to CMS PRA and the Tech Consortium highlight concerns about ongoing hospital noncompliance with HPT requirements and suggest actionable reforms to enhance data quality and enforce compliance.

Key recommendations include:

• Defining "accuracy" as the disclosure of actual, knowable dollar amounts, not estimates or placeholders.

• Defining "completeness" to include all charge types, services, and negotiated rates across all payers and plans. ​

• Mandating executive-level attestation for machine-readable files (MRFs) and treating misreporting as a material false statement.

• Leveraging Transparency in Coverage (TiC) data and other external sources to audit MRF completeness and flag discrepancies.

• Enhancing the CMS validator tool to detect blank fields, placeholders, and inconsistencies.

Read the full RFI and detailed recommendations.