Hospital Price Transparency Rule
Compliance deadlines
Machine-readable files (MRF)
Hospital data quality
CY 2026 OPPS Final Rule

-- min read

Updates to the hospital MRF landscape go live today, and here’s what hospital v3 data is already showing us

Early data shows 2,731 hospitals on v3, 1,956 with median allowed amount data on day one.

Updates to the hospital MRF landscape go live today, and here’s what hospital v3 data is already showing us

Authors

Ryan Kost
Senior Director, Data Foundations & Solutions Engineering

Hospital Price Transparency version 3 (v3) is live. As of this morning, 2,731 hospitals (and counting!) have published v3 MRFs and 1,956 have already populated the new median allowed amount field. Updated claims-based median allowed amount data is replacing the estimated allowed amounts that came before it and more updated MRFs are coming online as we speak. That's a meaningful foundation on day one, and it's exactly what iterative improvements in pricing data we expect as the price transparency landscape matures.

Here's what changed from v2 to v3, how we're tracking it, and what the early data is already showing.

v3 changes what hospitals are required to share

Hospital Price Transparency v3, finalized through CMS's hospital machine-readable file (MRF) requirements within CMS-1834-FC, went into effect today. The rule outlines changes in two broad buckets: new required fields and newly removed fields.

Six new MRF fields and requirements help move the data closer to true utility:

  • Attestation statement: replaces the old affirmation statement with a formal attestation and specific language
  • Attester name: the designated senior official signing off that the data is true, accurate, and complete
  • Type 2 NPI: the hospital's organizational National Provider Identifier
  • Median allowed amount: the median value of all allowed amounts from a defined look back period for a given payer/plan/item combination
  • 10th percentile allowed amount: the low end of the allowed amount distribution
  • 90th percentile allowed amount: the high end of the allowed amount distribution
  • Count of allowed amounts: the total number of remittance records used to calculate the percentile values above

Removed or updated fields include:

  • Affirmation statement: superseded by the new attestation
  • Estimated allowed amount (EAA): previously required as a way to report a dollar value for percentage or algorithm-based pricing

That last one, EAA, is the most consequential change from a data quality standpoint. The EAA was exactly as named: an estimate. Its replacement median allowed amount, by contrast, is derived from actual adjudicated claims, meaning real amounts a payer accepted for a specific item or service under a specific plan. Paired with the 10th and 90th percentile fields and a record count, v3 gives users not just an average but a meaningful view of the spread around it. In practice, that means you’ll see how much that figure varies across claims and how many claims it's based on. That's a fundamentally different and more useful kind of data. 

More useful data is the bridge to more useful patient experiences built on price transparency data. The v3 MRFs help usher in a new, higher standard of what it means to make a good faith effort toward transparency.

We built a free tool to track it v3 adoption real time

The question of adoption always comes up in the context of new regulation milestones. To answer it, we built and maintain the Hospital Transparency Tracker. Our publicly available, free tracker that now reflects adoption of v3 requirements in real time. Our usual reminder remains true with this tracker: only CMS can review a hospital MRF and determine compliance.  

The updated tracker checks for new .txt files on a weekly basis across hospitals nationwide, ingesting files as they're published and validating them against the required schema. You can see which hospitals have posted files, what schema version they're on, and other key metadata without needing a data science background to make sense of it. It's the fastest way to see where any hospital stands on v3 adoption today.

To use it, simply click on this link and filter to view your desired state’s technical requirement adoption.

3,137 hospitals are already on board

As of this morning, 3,137 hospitals have published MRFs that have the value “3.0.0” entered in the version field. Of those 3,137, 2,731 of those files are actually v3 schema valid, meaning the file structure correctly matches the v3 specification.

The roughly 400-hospital gap reflects a pattern we see during every schema transition. Some hospitals update their version field before fully updating the underlying data structure. We track both figures separately in our systems precisely because the version field and the actual file structure don't always match. Revising files in accordance with CMS requirements is no small feat, and it’s notable how many v3 files are already online as of day one. 

The new data is already telling us something

Of the over 2,700 hospitals that have posted v3 files, 1,956 have populated the median allowed amount field. That's a substantial foundation on the first day of enforcement. As expected, the number of individual percentile allowed amount records to vary by MRF, because only negotiated rates that are based on a percentage or an algorithm are required to include the percentile allowed amount fields.

The hospitals publishing robust median allowed data are already outpacing their prior EAA reporting, and the majority are still catching up. We expect these numbers to grow significantly as more hospitals post updated v3 MRFs.

v3 moves the whole industry forward

When all four new fields (median allowed amount, 10th percentile, 90th percentile, and count of claims) are populated, the data tells a richer story than any single dollar figure EAA could. That combination of reported data is what makes v3 a genuine step forward in MRF utility, not just a compliance update. The work hospital data and compliance teams are doing to meet these requirements has real downstream value for patients and the industry alike.

We'll publish regular updates as adoption grows. In the meantime, track it in real time on the Hospital Transparency Tracker.

The more complete and accurate MRF data becomes, the more useful the rates data built on top of it. If you want to work directly with the median allowed amount figures as they come in, Analyze is built on Clear Rates, our continuously updated pricing dataset that normalizes and validates MRF data across payers and hospitals. That's the kind of data that changes how you negotiate. Request a demo to see how it works.

Data current as of April 1, 2026. Hospital counts reflect our weekly ingestion pipeline.

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