The .txt file was the requirement CMS cited most often in its 27 price transparency fines

Penalty notices citing each requirement, of the 27 notices CMS posted from June 7, 2022 to June 3, 2026. A notice counts once per requirement, for the failures CMS found at its last review before the notice

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The .txt file was the requirement CMS cited most often in its 27 price transparency fines
ItemPenalty notices citing the requirement, of 27Note
.txt file missing from the website's root folder, or incomplete1212 of 27 notices; cited as 180.50(d)(6)(i), 180.50(d)(6)(i)(A)-(D)
No consumer-friendly list of shoppable services1111 of 27 notices; cited as 180.40(b)
No machine-readable file found99 of 27 notices; cited as 180.40(a), 180.50(a)
File not on the CMS template77 of 27 notices; cited as 180.50(c)(2)
Hospital name, license number and location not in the file77 of 27 notices; cited as 180.50(b)(2)(i)(A)
No "Price Transparency" link in the website footer77 of 27 notices; cited as 180.50(d)(6)(ii)
File leaves out items, charges, codes or locations66 of 27 notices; cited as 180.40(a), 180.50(a)(2), 180.50(b)(1), 180.50(b)(2), 180.50(b)(3), 180.50(b)(4), 180.50(b)(5), 180.50(b)(6), 180.50(b)(7)
File name does not follow CMS's naming rule66 of 27 notices; cited as 180.50(d)(5)
File not updated in the past year, or no update date66 of 27 notices; cited as 180.50(e)
Consumer-friendly list incomplete, out of date or not searchable55 of 27 notices; cited as 180.60(b)(3), 180.60(b)(4), 180.60(b)(5), 180.60(b)(6), 180.60(d)(2), 180.60(d)(3)(iv), 180.60(e)
Affirmation statement missing from the file44 of 27 notices; cited as 180.50(a)(3)(ii)
Charges split across more than one file33 of 27 notices; cited as 180.50(c)
Price estimator does not give the estimate the rule requires22 of 27 notices; cited as 180.60(a)(2)(ii)

About the data

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Method
Kent Applied read every penalty notice on CMS's enforcement actions page and coded each failure CMS cited at its last review before the notice to one of 13 requirements, by its plain-words description. Section numbers are kept as each notice cites them, because a 2024 rule renumbered parts of 45 CFR 180.50.
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