⚠ NOTICE: CMS v3.0 Enforcement Begins April 1, 2026 — Civil Monetary Penalties Apply to Non-Compliant Facilities
CMS Data Dictionary v3.0 · April 1, 2026 Enforcement

Secure Your Facility's
Safe-Harbor Status
Before the Deadline.

The ICD-11 transition was a massive lift. Now, CMS enforces v3.0 — moving from estimated rates to mandatory 12-month historical percentiles. Daily penalties begin this Wednesday.

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Calculate My Penalty Risk Request Immediate Engagement
Utilizing Standards From
CMS.gov 45 CFR §180.50 HL7 International HIMSS CMS HPT-Tool CLI v3.0
Risk Assessment Tool

CMS Enforcement Liability Calculator

Enter your facility's information to calculate your projected Civil Monetary Penalty exposure under the April 1, 2026 enforcement cycle.

RISK ASSESSMENT: CRITICAL
Projected Daily Penalty
30-Day Exposure
Annual Maximum Exposure

Standard v3.0 Deficiency Profile

Missing mandatory 10th / 90th / Median Percentile Allowed Amounts (v3.0)
Missing "Count of Allowed Amounts" per payer / plan combination
Type 2 Organizational NPI not present in file header
Senior Official Attestation Statement absent or using deprecated format
Secure Phase 1 Bridge Plan — Halt the Penalty Clock

* This assessment reflects standard v3.0 deficiency patterns. A formal audit of your specific MRF is included with engagement.

Our Engagement Model

The Two-Phase
Compliance Protocol

We understand that your team is already stretched following the ICD-11 transition. Our protocol is designed to remove this burden from your plate entirely.

1 Immediate · Within 24 Hours

The Safe-Harbor Bridge

Documentation your compliance office can file immediately as evidence of active remediation — typically sufficient to stay automated CMS Warning Notices.

  • Formal Regulatory Gap Analysis for your specific MRF
  • Remediation Roadmap for your internal compliance records
  • Pre-filled v3.0 Attestation Statement for website header
  • "Safe Harbor" letter establishing active technical engagement
  • Evidence packet structured for CMS audit response
2 14-Day Delivery

Full Data Transformation

Complete migration of your Machine-Readable File to the v3.0 schema — including statistical percentile calculation from your historical remittance data.

  • Ingestion of your 12–15 month 835/ERA remittance files
  • Calculation of mandatory 10th, 50th (Median), and 90th percentiles
  • "Tall" or "Plain" CSV schema encoding per CMS specification
  • Full validation via CMS HPT-Tool CLI Validator
  • Upload-ready file delivered to your IT / Webmaster team
Project Timeline

From Engagement
to Full Compliance

A defined, transparent timeline so your leadership team knows exactly what to expect at every step.

Day 1
Engagement & Safe-Harbor Filing
Phase 1 packet delivered. Attestation template live on your site. Remediation Roadmap filed as good-faith documentation.
Days 2–5
Secure Data Ingestion
Secure receipt of your EDI 835 / ERA historical payment files via encrypted transfer. HIPAA-compliant processing only.
Days 6–11
Statistical Transformation
Linear interpolation model applied to derive mandatory 10th, 50th, and 90th percentile allowed amounts per payer / plan combination.
Days 12–14
Validation & Delivery
Full schema validation via CMS CLI Validator. Upload-ready v3.0 MRF delivered to your webmaster with integration instructions.
Structured Relative to Your Risk Profile

Transparent Pricing.
Structured Like Your Penalties.

Because CMS fines are calculated by bed count, so is our fee. Every tier is designed so that your engagement cost represents less than 3 days of non-compliance exposure.

Tier 1
Small / Rural
≤ 30 Licensed Beds · CMS max: $300/day
Phase 1 — Bridge Plan $1,500
Phase 2 — Data Transformation $3,500
Secure Small Facility

Phase 1 cost = 5 days of CMS penalty exposure

Tier 3
Enterprise / System
> 550 Beds or Multi-Facility · CMS max: $5,500/day
Phase 1 — Bridge Plan $9,500
Phase 2 — Data Transformation $25,000+
Secure System Status

Phase 1 cost = 1.7 days of CMS penalty exposure

Phase 1 payable by credit card or wire transfer to initiate engagement. Phase 2 billed 50% at commencement, 50% upon delivery. Phase 2 pricing varies based on payer volume and file complexity. Contact us for a firm quote.

Leadership

Phillip Burnett

"Precision isn't a software update. It is a discipline built over 30 years of managing high-stakes systems where margin for error does not exist."

Phillip Burnett brings over three decades of operational leadership and high-stakes asset management to the healthcare compliance sector. Having directly managed a family medical facility, he carries firsthand knowledge of the complexities embedded in medical billing, insurance navigation, and regulatory accountability.

His career is defined by extreme precision — a discipline honed through 30 years of managing high-value yields and complex logistical systems where a single data error carries outsized consequence.

Phillip founded HPT Compliance Solutions to bridge the gap between raw billing data and federal regulatory transparency mandates. He recognized that while CMS requirements were growing in complexity, the technical tools available to most hospitals remained stagnant — leaving compliance teams exposed precisely when they were already stretched thin from the ICD-11 transition.

Based in North Bend, Washington, he serves facilities nationwide with a singular focus on risk mitigation and penalty avoidance. His approach combines veteran operational insight with automated, proprietary data transformation protocols — what he calls the "Last Mile" of compliance.

Common Questions

Frequently Asked Questions

Is CMS actually enforcing this on April 1st?
Yes. CMS formally delayed enforcement from January 1 to April 1, 2026 specifically to allow for this v3.0 transition. The April 1 date is not a soft guideline — it is when CMS begins issuing Warning Notices and initiating Corrective Action Plans for facilities with active deficiencies. Historical precedent shows they prioritize facilities already flagged in prior review cycles.
Why can't our EHR vendor (Epic / Cerner) handle this?
Most EHR platforms provide the raw data, but their v3.0 export modules are either backlogged or produce files that fail the CMS CLI Validator. The v3.0 percentile calculation requires custom statistical analysis of 12–15 months of historical ERA data — work that is not yet automated in most commercial systems. We specialize in exactly this "last mile."
What happens if we miss the April 1 deadline?
Facilities that have not updated typically receive a Warning Notice first, followed by a 45-day window to respond with a remediation plan. Our Phase 1 Bridge Plan is precisely that plan — structured to demonstrate good-faith engagement and documented progress. Without it, you are responding reactively to an enforcement timeline you don't control.
What does "Good Faith" documentation actually provide?
A formal Remediation Roadmap establishes a documented record that your facility was actively engaged in correction prior to the enforcement date. CMS auditors are required to consider evidence of active remediation in their penalty decisions. It does not guarantee waiver of fines, but it materially strengthens your position in any subsequent review.
How is our data protected?
We operate as a HIPAA Business Associate for the purpose of this engagement. All data is processed locally and never stored on third-party cloud infrastructure. We sign a Data Processing Agreement (DPA) immediately upon engagement. Your ERA / 835 files are deleted from our systems upon delivery of the completed MRF.
We just finished ICD-11. Can this wait until May?
We completely understand the ICD-11 fatigue — it was a significant operational lift for your HIM and coding teams. Unfortunately, HPT civil monetary penalties are daily and automated. They do not recognize internal resource constraints as a mitigating factor. The Phase 1 Bridge Plan is specifically designed to take this entirely off your plate so your team can focus on post-ICD-11 stabilization.
Immediate Engagement

Request Safe-Harbor Status
Before April 1.

Reply with your facility name, NPI, and licensed bed count and we will confirm your engagement within the hour. Time-sensitive inquiries are prioritized.

Email
p.burnett@hpt-compliance.com
Location
North Bend, Washington
Availability
Active Through April 1 Deadline
Send Engagement Request