Since our founding in 2020, Turquoise Health has advocated for hospital price transparency as a path to both empowering patients and fostering healthy competition in healthcare. Our efforts to track hospital price transparency efforts nationwide have been cited in the press, in research, and by the government. As recently as last year, an Op-Ed in Health Affairs from a team at CMS cited a Turquoise Health Impact Report’s figures as generally consistent with CMS’s internal assessment of MRF data quality nationwide.

Our intent is to use our parsing data to inform the public of hospitals’ significant efforts to publish price transparency data nationwide while drawing positive attention to price-transparent providers.

In spring of 2023, we advocated before Congress for the standardization of the hospital transparency schema. This would not only decrease burden and confusion for providers, but it would also make it easier for researchers, innovators and (indirectly) consumers to make practical use of the data. We eagerly prepared for the July 1st, 2024 rollout of these new technical requirements and created our MRF tracker to monitor adoption.

Findings, Learnings and a Planned Iteration for the MRF Tracker

In the first two weeks of July, we checked over 5,500 hospital websites and recognized over 1,600 hospitals for having met the new technical requirements. That said, as our MRF tracker received more attention, we heard valid feedback on a few details that left hospitals confused as to why they did not appear as “compliant” on our site. We understand these concerns and the overall sensitivity around hospital price transparency compliance. We are tweaking our process of detailing provider-specific results and will provide additional documentation of our methodology, a detailed FAQ, revised disclaimers, and more nuanced metadata to accompany our analysis.

That additional detail will be available this month. Our goals will be to 1) continue to highlight the efforts of transparent hospitals nationwide and 2) assist hospitals in meeting the new technical requirements in order to get ahead of compliance risk with CMS. In fact, since the launch of the MRF Tracker in July, we've privately corresponded with over two dozen provider organizations to diagnose and address valid problems with the requirements that would be easily observed by CMS through automated compliance validation.

Here is a summary of the feedback we received and issues we encountered (not an exhaustive list) - these issues and more will be addressed as we continue to iterate the provider list of the MRF Tracker:

We scanned the hospital's website before the requirements were met

  • In our blog in early July, we noted that CMS had issued a CMP on July 3rd citing non-compliance to the .txt requirement and we suspected they would be ramping up enforcement with the onset of the new schema requirement.
  • As the new requirement launched prior to a holiday weekend, we initially checked many hospital websites in the first week of July. We heard from some organizations that technical requirements were updated in the second or third week of July, and the Turquoise website needs to be refreshed. We will add additional clarification that clearly details our refresh cadence, and we will ensure to scan all hospital websites regularly throughout the month. We will also share additional metadata around the timing of our refreshes and clearly denote when a hospital is pending a refresh.

.txt files contained minor syntax errors that failed validation

  • Certain hospitals we heard from clearly intended to meet the txt file mandate, but may have left a minor syntax error that caused the .txt file to fail our validation. In these scenarios, we’ll acknowledge the presence of a .txt file and let the hospital know privately of the syntax error where appropriate, as this issue is easy and immediate to remediate.
  • Other hospitals placed the .txt file in the subdomain hosted by a vendor or on an individual hospital page (vs. a health system home page). We believe that either situation may be appropriate, and we’ll respond to hospital feedback to redirect where we look for the .txt file source.

Our usage of the word “compliance”

  • Since 2021, we’ve often published our opinion that CMS is the only arbiter of hospital price transparency compliance. That said, we find that it’s additionally helpful for third parties like Turquoise to publish public metadata in real time on hospital transparency efforts. Turquoise will never attempt to be the arbiter of compliance. When we launched V1 of our MRF Tracker, we used the word “compliance” specifically in the context of the two new technical requirements. This choice was misleading (especially when referenced out of context) and we will omit this word from future releases while adding additional disclaimer text that our statistics are specific to only certain requirements of the Hospital Price Transparency Rule.

Other feedback? Let us know

  • We’ve heard of a few other nuanced situations with the .txt file and v2.0 schema implementation, and we’re sure there are more. Drop us a line at info@turquoise.health to let us know of any additional feedback

We appreciate all the messages we’ve received on the MRF Tracker. Our team was thrilled to see such rapid adoption of the new technical requirements and will double down our efforts to highlight price-transparent hospitals on the Turquoise Health website. In doing so, we hope to continue to empower savvy consumers of healthcare.


If you’d like to learn more about our hospital price transparency efforts, discover how we help hospitals publish Machine Readable Files and explore our public documentation on Machine Readable File creation.