Study finds 23 Texas hospitals noncompliant with federal price transparency rules


Eli Kirshbaum


A recent study from evaluated a random sample of 500 US hospitals’ compliance with Affordable Care Act (ACA)-mandated price transparency requirements. It found 23 Texas hospitals — every surveyed hospital in the state — to be noncompliant.

The study, conducted between May 15 and July 8, 2021, assessed the hospitals’ compliance with the ACA’s hospital price transparency rule, effective Jan. 1, 2021. It examined whether they met two main requirements of the rule: to have a machine-readable standard charges list for all services and to have a charges list or price estimator tool for the 300 most common shoppable services.


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Three research analysts from examined each hospital’s website to see if they met these requirements. FireLight Health LLC — a company with expertise in hospital price transparency — conducted a separate review and validation of the report from July 2 to July 9, 2021, using “a substantial set of the data.”

A hospital was deemed noncompliant if it omitted any of the rule’s five standard charge criteria, if it posted blanks or zeros in data fields, if it didn’t post all negotiated payer rates associated with specific plans, or if the price estimator tool didn’t show both negotiated rates and discounted prices.

The Texas Hospital Association provided State of Reform with the following comment regarding these results:

“Texas hospitals support providing timely and accurate information to consumers about the cost of their health care. Many hospitals have developed and implemented cost estimators at their own expense, prior to the existence of any legal requirements to do so. Texas hospitals have been subject to voluminous new requirements effective this year to disclose negotiated rates with payors both at the federal and state levels. Hospitals are working diligently to comply with these new laws as fast as possible, and some have made more progress than others. Unfortunately, these requirements went into effect during an unprecedented pandemic that has strained all hospital staff – from caregivers on the frontlines to administrative employees.”

Noncompliant facilities included Houston Methodist Texas Medical Center, Baylor University Medical Center in Dallas, and Covenant Medical Center in Lubbock.

The report lists the areas in which the facilities failed to meet the rule’s requirements. Below is data from 10 of the 23 noncompliant Texas hospitals.