Federal hospital price transparency regulations, effective January 2021 and strengthened through subsequent enforcement guidance, require hospitals to post machine-readable files containing payer-specific negotiated rates for all items and services. Despite regulatory requirements, compliance rates across hospitals have been uneven, and even among hospitals that post MRFs, substantial variation in file format, schema, and completeness presents major challenges for downstream users attempting to construct usable datasets. This systematic review examines compliance status, data quality characteristics, and usability barriers across a nationally representative sample of hospital MRFs collected between 2022 and 2023, identifying the most common failure modes and their relative prevalence across hospital types and market contexts.
The analysis identifies four principal categories of data quality failure: structural non-compliance (files that do not conform to CMS schema requirements), rate completeness gaps (files that include some but not all required payer-specific rate entries), code-level errors (billing codes with mismatched format, invalid modifiers, or DRG grouper version inconsistencies), and accessibility barriers (files that are password-protected, require JavaScript execution to download, or are published in formats that preclude automated retrieval). Among the hospitals reviewed, 34 percent exhibited at least one material quality failure, with rate completeness gaps being the most prevalent issue. Safety-net hospitals and rural critical access hospitals showed significantly higher rates of structural non-compliance, likely reflecting resource constraints in compliance implementation. Large health systems with centralized revenue cycle functions demonstrated the highest rates of usable, complete file production.
For regulators, these findings suggest that enforcement focus should differentiate between structural non-compliance and rate completeness failures, as the two problem types call for different remediation approaches. For data users — including consultants, payers, and analytics vendors — the results underscore the need for a rigorous data validation and enrichment pipeline before MRF data can be used for benchmarking or market analysis. Recommendations include the adoption of standardized schema validation tools at the point of file ingestion, systematic cross-payer completeness checks, and collaborative data quality reporting mechanisms that give hospitals actionable feedback on their MRF production processes. Simple Healthcare’s data processing methodology addresses each of these failure modes as part of its standard pipeline.