| Course | HA 610 Health Policy and Management |
|---|---|
| Unit | Unit 3 |
| Paper type | Regulatory impact memo |
| Length | About 690 words, 4 pages |
| Format | Business memo with analysis, APA 7 references |
| School | Herzing University |
| Program | MS in Healthcare Administration |
| Updated | October 2026 |
Free sample paper for HA 610 Unit 3
Memorandum
To: Chief Financial Officer; Chief Compliance Officer
From: Administrative Fellow, Finance and Strategy
Date: January 30, 2026
Re: What the CY 2026 price transparency changes require of us, who owns each piece, and what they cost
The Answer First
The rule requires three new things of us, and we are ready for one of them. We must add percentile allowed amounts to the machine-readable file for services paid by percentage or formula, replace our affirmation statement with a named attestation by a senior official, and draw the new figures from remittance data over a defined look-back period. The attestation is ready to sign. The percentile data are not, and we have until April 1, 2026, when enforcement begins, to produce them. I recommend assigning the work to Revenue Cycle Analytics with a February 15 start, at a cost of about $70,000, and naming the CFO as the attester once the file passes an internal review.
The Rule
Issuing agency. Centers for Medicare & Medicaid Services [CMS]. Citation: 90 FR 53448, published November 25, 2025, inside the final rule with comment period that CMS issued for outpatient hospital and surgical center payment in calendar year 2026 (CMS, 2025). Effective date: January 1, 2026, with CMS stating that enforcement of the new data elements begins April 1, 2026. The changes amend the hospital price transparency requirements at 45 CFR Part 180, first established by the rule published in November 2019 (CMS, 2019).
Requirements, Owners, Deadlines, and Costs
Each row is one obligation.
| Obligation | Owning department | Deadline | Estimated cost | Current status |
|---|---|---|---|---|
| For payer-specific negotiated charges based on a percentage or algorithm, encode the median allowed amount and the 10th and 90th percentile allowed amounts, plus the count of allowed amounts, in the machine-readable file | Revenue Cycle Analytics, with Managed Care Contracting | April 1, 2026 | $55,000 (analyst time, file build) | Not started; affects 5 of 14 commercial contracts |
| Derive those amounts from electronic remittance advice or an equivalent source, with the look-back window running between one year and fifteen months before the file is posted | Revenue Cycle Analytics, with Patient Financial Services | April 1, 2026 | Included above; remittance data are held for 36 months | Data available; extraction query not built |
| Replace the affirmation statement with an attestation that the file is complete and accurate, naming the senior official who attests | Compliance; signer: CFO | April 1, 2026 | Minimal | Draft ready |
| Maintain documentation supporting the attestation for review if CMS asks | Compliance | Ongoing | $15,000 a year (internal review before each posting) | Process to be written |
What It Means for Us
Operationally, the rule turns an annual file update into a data project. For five contracts, the percentage terms cannot simply be posted; we must calculate what we were actually paid, at the median and at the 10th and 90th percentiles, for each service over the required look-back window. Our remittance data are good enough, but no one has built the query, and the result needs checking against contract terms before a senior official signs.
Financially, the direct cost is modest. The risk is larger. CMS can issue warning notices, require corrective action plans, and impose civil monetary penalties that scale with bed count, so a 180-bed hospital faces a larger daily figure than a small one; CMS publishes the enforcement actions it takes. National studies have shown that compliance with earlier versions of the rule lagged, particularly among smaller and independent hospitals (Jiang et al., 2022), and CMS has responded by tightening the requirements each year. A late or inaccurate file in 2026 is more visible than it would have been in 2021.
Personally, the attestation places accountability on a named individual. That is a reason to schedule an internal review before each posting and to document how each figure was derived.
Questions I Expect
Why not ask the payers for the figures? The rule places the obligation on the hospital, and payers calculate allowed amounts from their own data, which may not match ours; our remittance files are the defensible source. Why the CFO as attester? The attestation covers financial data drawn from revenue cycle systems that report to the CFO, and CMS asks for a senior official. Could we remove the five contracts from the problem by posting nothing for those services? No; the file must cover every item and service, and an incomplete file is exactly what the new attestation is designed to prevent. What if the query takes longer than planned? The fallback is to post the file on time with the percentile data for the three largest of the five contracts and a documented plan for the other two, and to tell CMS about the gap if asked, rather than to attest to a file we know is incomplete.
Recommended Next Steps
Approve the $70,000 first-year budget at the February finance committee. Assign Revenue Cycle Analytics to build the remittance extraction query by March 1, with Managed Care Contracting confirming contract terms for the five affected agreements. Schedule a compliance review of the draft file for March 20. Post the updated file and signed attestation by March 31. Revisit the five percentage-based contracts at renewal, since fixed-dollar terms would remove the need for percentile calculations entirely. The hospital is composite; the rule is cited as published in the Federal Register.
References
Centers for Medicare & Medicaid Services. (2019). Medicare and Medicaid programs: CY 2020 hospital outpatient PPS policy changes and payment rates and ambulatory surgical center payment system policy changes and payment rates. Price transparency requirements for hospitals to make standard charges public. Federal Register, 84, 65524. https://www.federalregister.gov/d/2019-24931
Centers for Medicare & Medicaid Services. (2025). Medicare program: Hospital outpatient prospective payment and ambulatory surgical center payment systems; quality reporting programs; overall hospital quality star rating; hospital price transparency; and notice of closure of a teaching hospital and opportunity to apply for available slots. Federal Register, 90, 53448. https://www.federalregister.gov/d/2025-20907
Jiang, J. X., Polsky, D., Littlejohn, J., Wang, Y., Zare, H., & Bai, G. (2022). Factors associated with compliance to the hospital price transparency final rule: A national landscape study. Journal of General Internal Medicine, 37(14), 3577-3584. https://doi.org/10.1007/s11606-021-07237-y
What the HA 610 Unit 3 instructions ask for
Unit 3 asks you to write a memo assessing a new regulation's impact on your organization. Expect to state the bottom line, identify the rule precisely, list each requirement with an owner, deadline and cost, explain operational effects, answer likely questions and recommend next steps. Students often ask how to estimate costs and which rule to use. Choose a recent final rule with clear operational effects. Cite the Federal Register citation and effective date. Estimate costs from staff hours, vendor quotes or comparable projects, stating assumptions. Assign each requirement to a named role. Lead with the answer, since executives read the first lines most closely. Keep the memo to two pages if possible.
How the HA 610 Unit 3 example is put together
The memo opens with the bottom line: three requirements, one already met. The rule section gives agency, citation, publication and effective dates. The requirement table lists owners, deadlines and costs with assumptions. The operations section explains how the work changes, from a yearly file refresh to an ongoing data pull from claims. The questions section answers four likely objections in a sentence or two each. The next steps section names a budget request, an owner and a date. The memo reads as a working document an executive team could act on at its next meeting, and every number traces to an assumption. Penalty amounts for missing the deadline are stated so the urgency is clear.
Reading the HA 610 Unit 3 rubric
Herzing's rubric for a regulatory impact memo usually covers the bottom line, accurate rule identification, the requirement table, operational analysis, anticipated questions and next steps. The requirement table with owners, deadlines and costs carries the most weight, since that is what an organization acts on. Bottom line points reward a clear opening answer. Rule criteria look for citation, agency and dates. Operational analysis earns credit when work changes are specific. Question points go to objections answered honestly. Next steps should be dated and owned. Cost assumptions stated plainly are often credited. The Federal Register rule at 90 FR 53448 anchors the memo. Penalties for missing deadlines, stated with amounts, are often credited because they set urgency.
Common HA 610 Unit 3 mistakes, and how to avoid them
Impact memos in HA 610 Unit 3 often slip by summarizing the rule without assigning owners or deadlines. Another frequent problem is costs without assumptions, so the finance committee cannot judge them. Students often bury the bottom line under background. The rule citation or effective date is missing. Operational effects are vague, such as more work for revenue cycle. Questions from executives are not anticipated. Next steps lack dates. Requirements already met are not identified, which overstates the work. Penalties for missing the deadline are left out, though they set urgency. Finally, lead with the answer and end with owned steps, because graders reward a memo an executive team could approve in one meeting.
Get a HA 610 Unit 3 example written to your instructions
Send the Unit 3 instructions and the rubric from your HA 610 classroom, along with the rule or agency you have been given and the setting your memo addresses. We write a custom example with obligations assigned to departments, costs split into categories and a dated decision list, returned in 24 to 48 hours. The first custom sample is free.
More HA 610 papers and healthcare administration samples
- HA 610 Unit 1: Policy brief
- HA 610 Unit 2: Legislative analysis
- HA 610 Unit 4: Stakeholder position paper
- HA 610 Unit 5: Public comment letter
- HA 610 Unit 6: Testimony statement
- HA 610 Unit 7: Advocacy plan
- HA 610 Unit 8: Policy recommendation memo
- HA 640 Unit 3: Demand forecast
- HA 645 Unit 3: Event reporting system audit
- HA 695 Unit 3: Organizational evidence review
- HA 620 Unit 3: Break-even analysis
HA 610 Unit 3 questions, answered
Which rules make good subjects for this memo?
Ones with operational teeth and a published effective date. Payment rules, conditions of participation, price transparency requirements, workplace safety standards and state licensure regulations all reach into daily operations, so the impact section writes itself from the text. Rules that only adjust an agency process give you little to assign to a department, which makes the second half of the memo thin.
Should the memo say whether the rule is good policy?
Rarely, unless the instructions ask for it. An internal impact memo exists to prepare an organization for a requirement that already exists, and editorializing about the rule can read as a substitute for the operational work. Where the organization plans to comment or to seek an exception, say that plainly in a short section near the end rather than throughout.
Does a memo still need citations?
Yes, and most sections will hold you to the same citation style used elsewhere in the course. Cite the rule itself, the agency guidance and any published analysis you rely on, placed where the claim sits. A professional format changes the layout of the document, not the requirement that a reader can trace every statement back to its source.
Where can I find a free HA 610 Unit 3 sample paper?
The full HA 610 Unit 3 regulatory impact memo is free on this page, the 2026 transparency changes mapped to owners, deadlines and costs. A memo on another rule can be prepared on request.
How do I write a regulatory impact memo for a hospital?
State the bottom line first, cite the rule precisely, list each requirement with an owner, deadline and cost, explain operational effects, answer likely questions and recommend dated next steps. This sample does that for a price transparency rule.