How Hospitals Can Generate and Maintain a CMS-Compliant Machine-Readable File (MRF) #
The CMS Price Transparency Rule requires all U.S. hospitals to publish their standard charges in a digital, machine-readable format. This file—known as a Machine-Readable File (MRF)—contains critical information about pricing and negotiated rates, and is intended to help patients make more informed healthcare decisions.
But while the intent is clear, the process of creating and maintaining an MRF can be complex. This guide walks through how hospitals can generate an MRF and keep it accurate over time.
What Is an MRF? #
A Machine-Readable File is a digital document (typically JSON or CSV) that lists:
- Gross charges (the standard list price)
- Discounted cash prices
- Payer-specific negotiated rates
- Minimum and maximum negotiated charges
This file must be updated at least annually, formatted according to CMS guidelines, and hosted in a publicly accessible location on the hospital’s website—without login or paywall restrictions.
How to Generate an MRF #
1. Identify Your Source Systems #
The data needed to build an MRF usually lives in the hospital’s existing systems, such as:
- Revenue Cycle Management (RCM) platforms (e.g., Change Healthcare, Waystar)
- Contract management solutions (e.g., nThrive, Cedar)
- Electronic Health Record (EHR) or billing systems (e.g., Epic, Cerner)
These systems contain the CPT/HCPCS codes, service descriptions, charge data, and negotiated rates necessary to populate the file.
2. Structure the Data Correctly #
CMS requires a specific structure for MRFs. Each service item must include:
- Service description
- Associated code (e.g., CPT, DRG)
- Payer-specific negotiated rates, listed per insurance plan
- Cash prices and other relevant pricing metadata
Many hospitals partner with specialized price transparency solutions—including CareCarta and other industry vendors—to ensure formatting and structure align with CMS specifications. These platforms typically offer automated validation and continuous monitoring to maintain compliance.
3. Publish the File Online #
Once the file is complete:
- Host it on your hospital’s website.
- Ensure it is accessible without login credentials.
- Provide a clear, visible link on a public-facing page labeled “Standard Charges” or equivalent.
CMS audits hospitals for compliance, including whether the file is actually downloadable and properly labeled.
Keeping the MRF Up to Date #
Required Update Frequency #
CMS mandates that MRFs be updated at least once every 12 months. However, hospitals should consider more frequent updates under these circumstances:
- Contract renegotiations
- New service offerings
- Rate adjustments or pricing corrections
Best Practices for Maintenance #
- Automate data extraction where possible to reduce manual overhead.
- Schedule regular internal reviews—quarterly or bi-annually can help catch issues early.
- Assign ownership to a specific team or department, often within Revenue Cycle or Compliance.
- Maintain version history to track what was published and when.
Beyond Compliance: Why It Matters #
Though MRFs are a regulatory requirement, they also represent an opportunity. Hospitals that approach transparency strategically can use this data to:
- Build patient trust
- Improve internal pricing visibility
- Develop direct-pay or out-of-network pricing strategies
MRFs are no longer just compliance paperwork—they’re a foundational asset in how modern health systems communicate value.
Final Thoughts #
For hospitals, the ability to generate and manage a CMS-compliant MRF comes down to alignment between systems, data, and accountability. With the right tools and processes in place, transparency doesn’t have to be a burden—it can become a competitive advantage.
Looking to streamline your MRF pipeline or gain deeper insights into your published pricing? Let’s talk.
Colin Atkinson is a medical coding expert and co-founder of Care Carta, with over a decade of experience in hospital administration systems.