The April 1 deadline has passed. CMS v3.0 enforcement is live. Facilities that haven't completed the transition to mandatory 12-month historical percentiles face daily civil monetary penalties — with no grace period remaining.
CFOs and compliance directors don't buy what they can't see. Here is every document, file, and deliverable produced under each phase — line by line.
A formal, citation-ready document identifying every v3.0 deficiency in your current MRF — mapped to the specific CMS regulation it violates. Structured for submission in a Warning Notice response.
The mandatory Senior Official Attestation, pre-filled with your facility's NPI, legal name, and attestation date — formatted to CMS specification and ready for immediate website posting.
A formal letter establishing that your facility is under active technical remediation engagement — structured to be filed with CMS in response to a Warning Notice or pre-emptively.
A complete, upload-ready Machine-Readable File built to CMS v3.0 specification from your historical remittance data — validated against the CMS CLI Tool before delivery.
The interactive report below is a representative example using fictional data. Every finding is expandable, every deficiency is cited to the specific CFR sub-section, and every remediation step is actionable. Your facility's actual report will look exactly like this.
Valley Ridge Medical Center
1400 Valley Ridge Boulevard
Springfield, OH 45501
NPI: 1234567890 · EIN: 31-4159265
Bed Count: 214 Licensed Beds
valleyridgemedical.org/standardcharges/VRMC_standardcharges.csv
Last-Updated-On field in file: 12/18/2024
Required update interval: Annual (§180.50(a)(3)(ii))
Days since last update: 127 days
12 compliance checks across §180.50 (MRF requirements) and §180.60 (consumer display). All checks performed against 45 CFR Part 180 current enforcement standards and CMS HPT FAQs dated March 24, 2026.
File identified as CMS template v2.0 format. Current requirement is v3.x (mandatory since January 1, 2025). Missing fields: npi, pct_10, pct_50, pct_90, estimated_amount_count.
VRMC_standardcharges.csv file header row does not contain the v3.x required columns pct_10, pct_50, or pct_90. The schema version field reads 2.0. This is the root deficiency from which the majority of other failures derive.npi field is absent from the file's general data element section. CMS requires the hospital's Type 2 (organizational) NPI — not an individual provider NPI — to be encoded as a general data element in the MRF header. Valley Ridge's Type 2 NPI is 1234567890.npi = 1234567890 in the general data elements section of the upgraded v3.x template.valleyridgemedical.org/standardcharges/VRMC_standardcharges.csv returns HTTP 200 and downloads without requiring user authentication, account creation, or any form completion. This satisfies §180.50(d)(3).| Hospital Size | Max Daily CMP | Applies to Valley Ridge? |
|---|---|---|
| ≤ 30 beds | $300/day | — |
| 31–550 beds | Beds × $10/day | ✓ Yes — 214 beds = $2,140/day |
| > 550 beds | $5,500/day | — |
npi = 1234567890, (b) hospital_type = general acute care, (c) the 2026 attestation text per §180.50(a)(3)(iii), (d) last_updated_on = today's date.[EIN]_Valley-Ridge-Medical-Center_standardcharges.csv. Confirm EIN beforehand. Apply the same convention to any JSON file also published.contact-name and contact-email fields. All four fields are mandatory per CMS guidance.VRMC_standardcharges.csv does not include the required EIN prefix. Required format: [EIN]_Valley-Ridge-Medical-Center_standardcharges.csvlast_updated_on field reads 12/18/2024. As of April 24, 2026, this file is 127 days past its required annual update window. Non-compliance for this item began on or around December 18, 2025.npi general data element field is not present in the file. This field, introduced in v3.x, must contain the hospital's Type 2 organizational NPI (1234567890 for Valley Ridge).pct_10, pct_50, pct_90, and estimated_amount_count are entirely absent. These require statistical processing of 12–15 months of historical EDI 835 remittance data.valleyridgemedical.org/price-estimate and does not require login to access. Satisfies §180.60(b) accessibility requirements. Recommend confirming tool covers minimum required services.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.
Documentation your compliance office can file immediately as evidence of active remediation — typically sufficient to stay automated CMS Warning Notices.
Complete migration of your Machine-Readable File to the v3.0 schema — including statistical percentile calculation from your historical remittance data.
A defined, transparent timeline so your leadership team knows exactly what to expect at every step.
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.
Phase 1 cost = 5 days of CMS penalty exposure
At 200 beds: Phase 1 cost = 2.25 days of exposure
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.
"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.
Reply with your facility name, NPI, and licensed bed count and we will confirm your engagement within the hour. Time-sensitive inquiries are prioritized.