The Year Healthcare Got a Little More Honest

It's December, which means it's time for the annual tradition of looking at the state of healthcare price transparency and trying to decide whether the glass is 21% full or 79% empty.

2025 was a strange year. Real things happened: actual enforcement actions, actual legislation, an actual fraud case involving pharmacy benefit managers that briefly made price transparency front-page news. And yet, the headline compliance number barely moved. Roughly 21% of hospitals are fully compliant with federal price transparency rules, the same stubborn number that's been hanging around for years.

So let's talk about what actually happened, and what it means going into 2026.

CMS Finally Started Writing Checks

The biggest news this year was CMS actually fining hospitals for non-compliance. Not warnings. Not strongly worded letters. Actual monetary penalties.

Ten hospitals received fines in 2025, with penalties reaching up to $310,000. In the grand scheme of hospital finances, these aren't bankrupting amounts. But the symbolic importance is hard to overstate. For years, the price transparency rule was widely regarded as toothless, a mandate with no real consequence for ignoring it. Hospitals had essentially called CMS's bluff, and CMS had blinked every time.

That dynamic shifted this year. The fines themselves may be modest, but they established a precedent that CMS is willing to act. And the hospitals that got fined are now required to come into compliance, with ongoing monitoring. It's not perfect, but it's not nothing.

Oklahoma Drew a Line in the Sand

While the federal government was taking baby steps, Oklahoma went and did something genuinely interesting. Senate Bill 889, signed into law in May, created state-level penalties for hospitals that fail to comply with federal transparency requirements. It also established a state-run audit process that doesn't depend on CMS enforcement.

This matters because it adds a second layer of accountability. A hospital in Oklahoma now faces potential penalties from both the feds and the state, and the state process is faster and more direct. Other states are watching closely. I've seen draft legislation in at least four other states that follows a similar model.

The Oklahoma approach also includes a consumer complaint mechanism, which is subtle but important. It means patients can directly trigger an investigation by reporting non-compliant hospitals. That's a fundamentally different enforcement model than relying on CMS to audit 6,000+ hospitals with limited staff.

The PBM Fraud Case

In September, a federal investigation revealed that a major pharmacy benefit manager had been systematically inflating drug prices and pocketing the spread between what insurers paid and what pharmacies received. The case involved hundreds of millions of dollars in overcharges.

This isn't directly about hospital price transparency, but it matters for the broader conversation because it showed the general public something that people in this space already knew: the pricing intermediaries in healthcare are not always acting in patients' interests. PBMs are supposed to negotiate lower drug prices on behalf of insurers and employers. Instead, this one was doing the opposite.

The case got mainstream media coverage, and for a brief moment, normal people were talking about healthcare pricing opacity. It helped build public awareness that the system is not set up to give you the best price, and that transparency, actual transparency and not the curated version, is the only real check on these incentives.

What Didn't Change

For all the progress in 2025, the fundamental numbers are stubbornly flat. Hospital compliance with price transparency rules is still around 21%. The majority of published machine-readable files still have significant quality issues. And most patients still have no idea they can compare hospital prices before a procedure.

The data quality issue is particularly frustrating from my perspective working on Panopticare. We're now ingesting and normalizing data from over a hundred hospitals in the Chicago area, and the variation in file quality is staggering. Some hospitals publish clean, well-structured files that are straightforward to parse. Others publish files that technically exist but are full of duplicates, internal codes, or prices that are clearly wrong. One hospital listed every single procedure at $1.00. Another published a file with 40,000 rows where every price was $0.

Compliance isn't just about whether a file exists on a website. It's about whether the data in that file is accurate and usable. By that stricter standard, the real compliance rate is probably even lower than 21%.

Looking Ahead to 2026

The new CMS requirements taking effect on January 1, 2026, are the strongest yet. Higher penalties, tighter technical standards, and new requirements around payer-specific rates. The ACA subsidy expiration is going to push millions more people into high-deductible plans where they have a direct financial interest in comparing prices.

I think 2026 has the potential to be the year where price transparency goes from a regulatory curiosity to something that actually affects patient behavior. The pieces are falling into place: better data, stronger enforcement, more consumer exposure to real prices, and tools that can actually make sense of the information.

But I've been wrong before. If 2025 taught me anything, it's that progress in this space is measured in inches, not miles. The institutions that benefit from opacity are large, well-funded, and highly motivated to maintain the status quo. Change is happening, but it's happening slowly, messily, and with a lot of resistance.

Still, inches in the right direction are better than standing still. And looking at where we were a year ago versus today, we've moved forward. Just a little more honest. Just a little more transparent. One hospital fine, one state law, one fraud case at a time.