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The Largest Price Transparency Fine Yet: How UF Health North is Out Almost 1M And What Rev Cycle Leaders Can Learn

Analysis  |  By Amanda Norris  
   September 15, 2023

In the largest price transparency fine yet, University of Florida Health North was docked $979,000 by CMS.

UF Health North received a $979,000 price transparency fine due to several compliance violations under the No Surprises Act—a big reminder that revenue cycle leaders need to be prioritizing compliance.  

According to CMS, UF Health North failed to uphold several requirements under the price transparency requirement:

Failure to update standard charge information annually: Hospitals are required to update the standard charge information annually. UF Health North failed to do so, leading to noncompliance.

Incomplete data elements in the list of standard charges: Hospitals must include all corresponding data elements in the list of standard charges, including descriptions for each item and service, payer-specific negotiated rates, and de-identified minimum negotiated charges. UF Health North did not fully adhere to these requirements, CMS says.

CMS is making it clear that noncompliant organizations are going to be penalized. In fact, the number of fined organizations has now reached 14.

As the number of fined organizations is sure to grow, revenue cycle leaders need to make sure to streamline price transparency strategies.

Here are a few tasks that revenue cycle leaders need to make sure are prioritized:

Regularly update pricing information: Revenue cycle leaders should establish processes to ensure that standard charge information is updated by revenue cycle teams at least once annually, as mandated by CMS. This involves keeping track of changes in charges for services and items.

Comprehensive data inclusion: This is an area UF Health received the most dings, so leaders need to meticulous in making sure all relevant data elements in your list of standard charges is present. This includes descriptions, payer-specific negotiated rates, and deidentified minimum negotiated charges.

Implement or streamline shoppable services display: Organizations need to have a user-friendly online display of shoppable services, making it easy for patients to access and understand pricing information for common procedures.

Conduct regular compliance audits: Hospitals should conduct routine self-audits to assess their compliance with price transparency regulations. Really, audits should be in place for all compliance regulations. Also, make sure to identify and rectify any deficiencies promptly.

Educate staff: Your entire revenue cycle staff—from front end to backend—should be well-informed about the importance of price transparency compliance and trained to provide patients with accurate cost information.

Engage legal and compliance experts: The revenue cycle isn’t siloed. Continually seek the advice of the legal and compliance experts in your organization (or even outside your organization if necessary).

Stay informed: Revenue cycle leaders should be staying up-to-date with evolving regulations related to price transparency. Regulations in general are everchanging, so staying abreast of even the most mundane regulations can save you big in the long run.

Respond promptly to CMS notices: If your organization receives a notice of noncompliance from CMS, it is crucial to respond promptly and take corrective actions as required.

Amanda Norris is the Associate Content Manager of Finance, Payer, Revenue Cycle, and Strategy for HealthLeaders.


CMS is making it clear that noncompliant organizations are going to be penalized, and the number of fined organizations is sure to grow.

There are eight tasks that revenue cycle leaders need to make sure are prioritized to avoid an outcome like UF Health North.

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