March 4, 2025 - Alerts and Newsletters

        Healthcare Costs Demystified: Trump’s New Executive Order on Healthcare Price Transparency Explained

        President Trump’s Executive Order 14224 reinforces and expands a 2019 Executive Order which aimed to improve healthcare price transparency. On February 25, 2025, President Trump signed a new 2025 Executive Order entitled “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information” to address compliance issues with the 2019 requirements. The purpose of the new order is to promote access to clear and accurate healthcare prices by increasing enforcement and identifying opportunities for greater price transparency.

        President Trump’s 2019 Executive Order and subsequent rules required the following:

        • Hospitals to maintain a consumer-friendly display of pricing information for up to 300 shoppable services, as well as a machine-readable file with negotiated rates for every service provided by the hospital;
        • Health plans to post their negotiated rates with providers, including their out-of-network payments to providers, as well as the actual prices that they (or their pharmacy benefit manager) pay for prescription drugs; and
        • Health plans to maintain an online tool for consumers to access price information.

        Under the 2025 Executive Order, the Departments of the Treasury, Labor, and Health and Human Services must implement the following actions by May 26, 2025 in order to enforce the healthcare price transparency regulations:

        • Require the disclosure of the actual prices of items and services – not estimates;
        • Issue updated guidance or proposed regulatory action to ensure standardized and easily comparable pricing information across hospitals and health plans; and
        • Issue guidance or proposed regulatory action updating enforcement policies to ensure transparent reporting of complete, accurate, and meaningful data.

        Both the 2019 and 2025 executive orders emphasize the Trump Administration’s goal to empower patients through healthcare pricing transparency. Hospitals and health plans should prepare for a stronger emphasis on enforcement and accountability.

        In advance of federal enforcement and standardized pricing guidance, hospitals and health plans should review price transparency policies and processes, and begin taking the following steps towards compliance:

        • Regular Updates: Regularly update the pricing information to reflect any changes in costs, negotiated rates, or service offerings.
        • Training and Education: Train staff on the requirements of the Executive Orders and how to implement the necessary changes. This should include an understanding of how to use, maintain, and provide consumer-facing disclosures of pricing information.
        • Ongoing Compliance: Establish systems for ensuring compliance and reporting any issues. This can help identify and address any gaps in the implementation of the Executive Orders.

        Verrill continues to monitor these legal developments to guide hospitals and health plans in meeting their compliance needs.

        Verrill is a full-service law firm with industry-recognized health care and corporate attorneys who represent institutional providers and business entities of all sizes in transactional, strategic counseling, financial, and regulatory matters. For more information, please contact Andrew Ferrer, your Verrill relationship partner, or another member of Verrill’s Health Care & Life Sciences team.[1]


        [1] This article is a summary of certain health care regulatory matters for informational purposes only and does not constitute legal advice. For more information, please contact us.

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