Warnings are common. Fines are rare. The clock is the problem.

CMS began enforcing the rule on April 1, 2026, and the number that travels is the penalty ceiling: a statutory range of $109,500 to $2,007,500 a year. It is real. It is also rare.

Overwhelmingly, what CMS issues is a warning notice, not a penalty. Most hospitals that receive one correct their file and reach closure without ever being fined. Selling a hospital on the fine is selling a lottery ticket in reverse. It's the wrong number to fixate on.

A civil monetary penalty accrues daily, from the warning date, until the file is corrected. CMS may keep imposing penalties until full compliance. The exposure is not a lump sum; it is a meter running while a file sits broken and nobody at the hospital knows.

The daily rate is set by bed count: $300/day for 30 or fewer beds, $10/bed/day between 31 and 550 beds, and $5,500/day above that. Multiply by the days a file stays out of conformance and you have the real cost curve. It is a function of time, not of bad luck.

The published penalty notices are documents, not rumors, and they tell the same story. One small facility drew $300/day across 197 days for $59,100. Another drew $300/day across 338 days for $101,400. The daily rate was modest; the duration is what made the total.

The median imposed penalty sits near $93,214. In every case the lever was the same: how long the file stayed wrong.

There's a second myth worth correcting: that the danger is a moving regulation. It isn't. The rule is stable. What moves is your data, your rates, your file. A conforming file quietly falls out of conformance as contracts change and dates go stale, and the first anyone hears of it is an angry patient or a warning letter.

That's the case for watching the file continuously and regenerating it when it drifts, rather than checking it once a year and hoping. The cheapest day to fix a file is the day it breaks, not the day the clock has been running for six months.