PRA Submits OPPS Comment Letter With Specific Recommendations to Improve Price Transparency

PRA submitted a comment letter to CMS in response to its proposed 2026 OPPS rule, offering specific recommendations to enhance the Hospital Price Transparency Rule to make it more useful for American healthcare consumers. 

PRA's new Semi-Annual Hospital Price Transparency Compliance Report demonstrates why our recommendations are urgently needed: Only 15.5% of hospitals reviewed were found to be sufficient in the disclosure of dollars-and-cents prices, meaning more than 50% of their negotiated charges were expressed in a dollar amount. Hospital price transparency is moving in the wrong direction. In comparison to findings in PRA’s Seventh Semi-Annual Hospital Price Transparency Report in November 2024, 43.5% of hospitals reviewed decreased the number of actual prices they posted.

To truly empower consumers with upfront prices to choose the best care at the best prices and protect their personal and financial health, CMS should:

1) Require Real Dollar Prices. Hospitals must post actual prices in dollars and cents—not vague formulas or percentages—so patients know what care will cost upfront. When a price cannot be expressed as a dollar amount, hospitals must provide all necessary information for an average patient to determine the dollar amount without the need for third-party assistance.

2) Disclose Full Contract Terms. Price files should include all carve-outs, stop-loss provisions, and other exceptions, not just base rates, which are often only a fraction of the actual prices paid, so meaningful price comparisons within and across hospitals can be made.

3) Report Accurate Discounted Cash Prices. Hospitals must publish accurate discounted cash prices, which are increasingly important to consumers, including uninsured patients, those paying out of pocket, and self-insured employers.

4) Post Provider Identifiers. Hospitals should list their Type 2 National Provider Identifiers (NPIs) to improve accountability by giving patients and employers access to additional information about their providers through the NPI Registry and alternative sources.

5) Require Executive Attestations. A senior hospital officer should certify the accuracy of published prices to prevent misleading or incomplete disclosures, including inaccurate and unaccountable “estimates.”

6) Enforce the Rule, Don’t Weaken It. CMS should withdraw its proposal to reduce penalties for noncompliant hospitals that waive their right to a hearing and instead increase enforcement and penalties to ensure real accountability.

Read the full comment letter here.