Centers for Medicare & Medicaid Services (CMS) Price Transparency Report 3.0

Bringing attention to the pricing discrepancies between independent and hospital-based facilities on the same levels of care

The cost of medical care can vary significantly depending on where a patient receives treatment

Independent clinics often offer lower, more predictable pricing, while hospital-based practices charges higher facility fees, co-payments, and deductibles. Yet, patients are rarely aware of these differences, leading to unexpected costs and financial strain.

**Understanding these pricing discrepancies is necessary for informed healthcare decisions**

This analysis explores the impact of price transparency in healthcare and why patients deserve clear, upfront information about the cost of their care.

Distribution of ASC (Independent) & HOD (Hospital Based) Diagnostic Centers in Northern Virginia

Data Source: Health Systems Agency of Northern Virginia – CT/MRI Reports 2020

This visual highlights the disparity in access of diagnostic care centers (independent, hospital-based, Kaiser).
There are nearly five times more hospital-based centers than independent practices
Notice how wealthier counties tend to be more populated with hospital-owned facilities.

Cost Comparison for Diagnostic Codes ASC (Independent) vs. HOD (Hospital Based) in Northern Virginia

Data Source: Procedure Price LookUp – Medicare.gov

This visual presents the cost breakdown comparison of independent and hospital-based centers charges per diagnostic code between 2024 and 2025.
It is significant to mention: While the facility fees and patient co-pay increases, doctors fee charges decrease.

Semi-Annual Hospital Price Transparency Compliance Report – November 2024

Check which hospitals are compliant with the federal hospital price transparency rule under the authority of the Affordable Care Act (ACA).

Based on Medicare Procedure Price Lookup Tool

COPN - Certificate of Public Need

“The program seeks to contain health care costs while ensuring financial viability and access to health care for all Virginia at a reasonable cost.”

– Virginia Department of Health

Reality:

In Virginia, the application filing fee can cost up to $20,000 without a guarantee of approval.
In the Commonwealth, COPN laws have incentivized large hospital systems to monopolize outpatient diagnostic imaging and surgical services by restricting competition among non-hospital/independent providers, particularly in affluent markets, such as Northern Virginia.

Implications:

COPN regulation has failed to reduce unnecessary healthcare spending. Instead, it has increased costs of outpatient diagnostic and surgical services.
Systematically given large hospitals and health systems the power to eliminate competition by allowing them to oppose projects they view as a threat to their existing services.

Action:

Beyond cost, specifically in Northern Virginia, COPN regulation has given hospital systems, the latitude to create monopolies and thwart competition in communities where they have dominant market presence. Legislators should seriously consider removing COPN regulation.
Encourage the initiation of lower-cost facilities
Expand independent access points of care.

Impact of increasing diagnostic and surgical services in hospital-based facilities

Single

2023 Total Annual Premium: $8,144.
50.5% increase from 2013 to 2023 in Total Annual Premium.

Family

2023 Total Annual Premium: $24,251.
52.4% increase from 2013 to 2023 in Total Annual Premium.

Moving the bar to the left unveils the average annual single premium.

Moving the bar to the right unveils the average annual family premium.

Figure 1 & 2. Kaiser Family Foundation

Executive Order on Healthcare Price Transparency

On February 25, the White House issued an Executive Order to improve healthcare price transparency, ensuring patients have access to clear, accurate, and actionable pricing information.

In response, the Departments of the Treasury, Labor, and Health & Human Services will:

Require hospitals and insurers to disclose actual prices—not estimates—including for prescription drugs.
Strengthen enforcement to ensure compliance with price transparency regulations.

Resources for Hospitals

CMS offers tools to assist with compliance:

Hospital Price Transparency Tools – Includes an Online Validator to check machine-readable files and the HPT TXT Generator for required data formatting.
Data Dictionary (GitHub Repository) – Provides templates, technical instructions, and support for encoding pricing data.

Hospital Price Transparency Requirements

Under existing CMS regulations, hospitals must provide:

A machine-readable file listing standard charges for all items and services.
A consumer-friendly display of shoppable services for easy comparison.

Compliance & Enforcement

CMS is enhancing its monitoring and enforcement efforts in line with the Executive Order. Non-compliance will result in swift action, with enforcement activities and outcomes published quarterly.

For additional guidance, email PriceTransparencyHospitalCharges@cms.hhs.gov.

Take Action!

Every patient deserves access to clear and accurate healthcare pricing. If you believe in holding hospitals and insurers accountable, now is the time to act!

Contact your legislator and urge them to support stronger price transparency enforcement.

Find your representative – Enter your home zip-code to find your Virginia Senate and House legislators.
Sign the petition – We’ll submit petitions monthly to amplify our voices.