The CEO attestation requirement, explained

Under the CY2026 OPPS final rule, every hospital's machine-readable price transparency file must encode an attestation: a statement, affirmed by the CEO, president, or another senior official the hospital designates, that the data in the file is true, accurate, and complete as of the date published.

This is a real change from prior years. Before 2026, hospitals published a generic compliance statement with no named individual behind it. Now the file itself carries a name, and that name is legally attesting to the file's accuracy the same way an executive signs a financial statement.

What the attestation actually says

The CMS-specified language affirms that the hospital has included all applicable standard charge information required by 45 CFR 180.50, that the information is true, accurate, and complete as of the file's date, and that every payer-specific negotiated charge is either expressed as a dollar amount or, where that is not possible, backed by the underlying fee schedule, algorithm, or formula needed to derive it.

Why this raises the stakes

A missing or malformed attestation block is not a cosmetic error. It means nobody is actually on record attesting to the file, and it is one of the highest-severity checks CMS reviewers look for. Before this change, a hospital's compliance officer could quietly fix a broken file. Now, if a named executive has already signed off on a file with errors, the fix has to be paired with a correction to what they attested to.

What to check before anyone signs

• The attestation statement is present and matches the CMS-specified language exactly.
• The attester's name is populated, not blank or a placeholder.
• The confirmation flag (or its equivalent in the CSV encoding) is actually set to true.
• The rest of the file is clean: an attestation on a file full of blockers puts the signer at more risk, not less.

MRF Preflight checks all of this automatically under rule HPT-L2-030.