Non-compliance to price transparency can result in significant fines

As we begin the second year of expanded Price Transparency, the healthcare industry faces a multi-pronged public relations assault. CMS and the press are now identifying hospitals that have failed to meet CMS regulatory mandates. This special series of ChargeAssist® Update News focuses on root causes of the growing negative image of our industry relative to prices. This is part three of our three-part series on Price Transparency’s impact on hospital reputations and public relations.

Price Transparency Part 3 : The Cost of Non-Compliance

Fines increase in 2022

Hospitals failing to meet CMS mandates are not only being called out in the news; they are also being contacted for corrective action plans and risk mounting fines. Updated Civil Monetary penalties for 2022 are noted below:

Expect more news in 2022 as CMS expands its monitoring, warning notices, corrective action plans, and ultimate fines. To be prepared, hospital teams should review regulatory language authorizing the CMS actions. See the link below for the Code of Federal Regulations text and Exhibit B of this article for full regulatory text.

When CMS identifies a hospital that is not in compliance, it will provide notice and require a plan of action that the organization must adopt. Documents called “Corrective Action Plans” may be required. CMS has provided a Corrective Action Plan Response sample here:

CMS is also seeking Hospital Price Transparency complaints from the public through a new website portal. Their link is found below. We suspect that the general public will soon become aware of just how easy it is to report hospitals, and hope that the website isn’t abused by unscrupulous parties. 

With today’s multi-faceted enforcement campaign, the impact on hospitals’ images will be interesting to monitor as CMS moves forward with its plan for collecting complaints and publishing information on bad actors.

Looking Ahead

As noted in 2021 surveys, the general public doesn’t typically recognize the challenges Price Transparency regulations have forced upon our nation’s hospitals. As providers experience the costs, data compilation challenges, and man-hour commitments that CMS failed to forecast, it’s easy to be discouraged.

In this three-part series, we’ve shared details on important aspects of CMS Price Transparency, including the preponderance of negative press, the costs of delayed implementation, and today’s punitive approach of government. The new cost of non-compliance may include fines, time required for CMS action plans, and crafting responses to continued press, patient, and public complaints.

In a time when hospitals should be appreciated for their heroism, we see, instead, renewed negative press. Public relations challenges on the pricing topic are not only a nuisance, but can also damage reputations and discourage hospital staff. As Price Transparency is slowly adopted, proactive organizations will shine, while those failing to address the regulations will most likely regret their slow action.


Holliday & Associates offers ChargeAssist®; an HFMA Peer Reviewed™ Charge Master auditing and resource tool for easily auditing, collaborating, and maintaining Charge Master files. We also provide Charge Management Education and CDM Reviews by a team of credentialed clinical, coding and technical auditors. Contact information: (800) 831-3323 | Web Site: |

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