Six hospitals,
five files,
two of them copies.

Braden Health operates five open hospitals and one closed facility that is being rebuilt. Each one enrolls with Medicare under its own single-purpose corporation, which means no corporate identifier ties them together in CMS data, and the portfolio has to be assembled facility by facility.

Two of the five are short-term acute care hospitals and three are Critical Access Hospitals. That distinction moves the penalty ceiling, though it changes nothing about what has to be published. None of the six is a Rural Emergency Hospital. Every facility carries REH conversion flag = N in CMS Hospital Enrollments, so the REH pathway and its separate reporting regime never come into play.

Public reporting describes the group as having "about seven critical access hospitals." The five open facilities above are confirmed. Any others could not be identified from public data, because the single-purpose-corporation structure leaves no searchable link between them. Searching CMS Hospital Enrollments for "Braden" returns nothing at all.

All five open hospitals publish a machine-readable file, and all five do the mechanical part correctly. Every file is CSV tall, schema version 3.0.0, carries the CY2026 attestation, a named attester and a Type 2 NPI, and is reachable from a valid /cms-hpt.txt at the domain root.

The gaps that follow are all in the data those files carry.

Comparing the files row by row, two pairs turn out to be one file each. This is the most consequential finding in the review, because a shared file implies a shared chargemaster and shared negotiated rates across facilities that hold separate licenses, separate CCNs and separate contracts.

Section 180.50 governs the machine-readable file. Since 1 January 2026 it has also required a formal attestation, a named senior official and a Type 2 NPI. Where a rate is expressed as a percentage or an algorithm, it requires the median, 10th and 90th percentile allowed amounts as well, plus a count of the remittances behind them. CMS began enforcing those additions on 1 April 2026.

Section 180.60 requires a consumer-friendly display of 300 shoppable services, including 70 that CMS specifies. A hospital can satisfy it with a published list, or it can be deemed compliant under 180.60(a)(2) by running a price estimator that covers the same 300 services and tells a patient what they will owe.

All six Braden sites take the estimator route, and none of them publishes a shoppable services list.

CMS publishes every enforcement action it takes. Three of the five open Braden hospitals currently carry an open warning notice. Henderson has been through the cycle three times and is in it for a fourth.

Perry County and Stuart have no enforcement history. Both enrolled with Medicare only this year, and neither appears to have been reviewed yet, so the empty record probably reflects timing more than anything else.

Penalty exposure, if it ever gets there

Under 180.90(c)(2)(ii) a hospital of 30 beds or fewer is capped at $300 per day; a hospital of 31 to 550 beds pays $10 per bed per day.

The CY2026 rule is already in force and already being enforced. The CY2027 proposed rule leaves Part 180 untouched, though it does ask a question that would change how every Braden hospital satisfies the consumer display requirement.

Already in force

The CY2026 OPPS final rule took effect 1 January 2026, with enforcement from 1 April 2026. It replaced the single estimated allowed amount with the median, 10th and 90th percentile plus a remittance count; required a formal attestation in fixed statutory language; required a named senior official responsible for the encoding; and required Type 2 NPIs. Braden's files carry all four.

Proposed, though Part 180 is untouched

CMS-1850-P was published at 91 FR 41734 on 7 July 2026, with comments closing 31 August 2026. The parts it proposes to amend are 42 CFR 413, 416, 419, 427 and 488. 45 CFR Part 180 is absent from that list. Hospital price transparency appears only as a Request for Information, so this rule creates no new obligation and CY2026 remains the standard to build against.

The question inside the RFI

The RFI asks whether CMS should stop deeming hospitals compliant when they run a price estimator. In CMS's words:

Braden's entire consumer-display position rests on 180.60(a)(2). If CMS acts on this, every hospital in the portfolio would need a shoppable services file, and the estimator would become a patient-experience product instead of a compliance instrument. Nothing obliges that today and rulemaking is slow, but it does argue for generating the estimator and the file from one source. That also happens to be the cheapest way to keep the two from contradicting each other.

The MRF half of the RFI points the same direction. CMS is asking about standardizing payer and plan naming, citing "Blue Cross, BlueCross, BC, and BCBS" as the problem; about parsing free-text fields; and about encoding outlier, stop-loss, rate-tiering and carve-out terms. It says outright that it anticipates "proposing additional requirements through future notice and comment rulemaking."

Eight things could not be settled from outside. Each one changes what remediation actually involves, and several of them could soften the findings above once answered.

Every hospital-specific figure was read directly from the live published files on 9 September 2026: the five CSVs, the five cms-hpt.txt files, the estimator datasets and the HTTP response headers. File comparisons were run row by row over parsed CSV. Facility characteristics and enforcement history come from CMS's own published datasets. Regulatory text is quoted from the eCFR as current to 31 August 2026, and from the Federal Register text of the proposed rule.

No compliance tracker or third-party aggregator was used as a source for any claim, and nothing here relies on a vendor's assessment of a competitor.