Indiana put a metric into law and provided the data to track it.
The share of more than 108,000 benchmarkable list prices published by Indiana's major hospital systems that currently sit above 260% of the corresponding Medicare rate.
Indiana has enacted the most direct hospital pricing law in the country. House Enrolled Act 1004 requires the state's largest nonprofit hospital systems to offer employers health care arrangements priced at or below 260% of what Medicare pays. The largest systems have been subject to that requirement since September 1, 2025. Independent hospitals reach their compliance date on September 1, 2026. A separate provision, with a June 30, 2029 deadline, ties the nonprofit status of the largest systems to a statewide price benchmark.
Hospitals have also been federally required to publish their standard charges since 2021, and Medicare's payment rates are public record. That makes a simple question answerable from public information: how far do the prices hospitals publish sit from the number the law made famous?
The Solomon Report measured it.
The design is notable for what it does not require: no new rate-setting agency, no negotiation, no waiting on federal action. It takes numbers that already exist in public, Medicare's rates and the prices hospitals report, and draws lines against them.
By the state's own review published in April 2026, the direct-to-employer arrangements of all five covered systems came in at or below the 260% mark. Where the law reaches, the numbers are under the line.
Across the major hospital systems operating in Indiana, 86.8% of the more than 108,000 published list prices that can be directly benchmarked against a Medicare rate currently exceed 260% of that rate. The figure is computed conservatively: each price is compared against the higher of Medicare's applicable payment rates for the same billing code, so a price is counted as above the line only when it exceeds 260% of the most generous Medicare figure available.
List prices are not the negotiated rates the statute's employer provision governs. They are the published charges that anchor bills for self-pay patients, out-of-network care, and the starting position of most billing disputes. The arrangements the law regulates have come in under the line, while the published prices that meet an ordinary patient sit above it in nearly nine cases out of ten.
A comprehensive metabolic panel, one of the most commonly ordered blood tests in American medicine, illustrates the range:
| Comprehensive metabolic panel (CPT 80053) | Price |
|---|---|
| Lowest published list price, major Indiana systems | $60.00 |
| Highest published list price, major Indiana systems | $690.86 |
| Medicare payment rate | $10.56 |
| 260% of Medicare | $27.46 |
The same test. The same state. An 11-fold difference depending on which door a patient walks through, and a top price more than 25 times the level the law contemplates.
A published list price above 260% of Medicare is not a violation of HEA 1004. The statute's 260% benchmark governs the pricing of direct-to-employer arrangements, computed under the statute's own methodology from the prices actually paid under those arrangements. The separate nonprofit status provision, with its June 30, 2029 deadline, uses a statewide average benchmark, not a fixed 260% line. Enforcement determinations belong to the State of Indiana, not to this report.
What the finding does establish is the size of the adjustment the law implies. If the prices hospitals publish today are the starting point, the gap between current practice and the statutory benchmark is the dominant feature of the data.
It also establishes something simpler: the question the law poses can be answered from public information. Any patient, employer, journalist, or legislator can ask how far a given price sits from the Medicare benchmark, because both numbers are published.
September 1, 2026 applies to Indiana's independent hospitals and is seven weeks away as this report is published. The largest systems have been subject to the employer contracting requirement since September 2025, and the nonprofit status deadline for the largest systems arrives June 30, 2029.
The Solomon Report intends to keep measuring.
Solomon Report findings are computed from hospitals' federally required price transparency files and public Medicare fee schedules. Findings compare published hospital charges for a given billing code against Medicare's payment rates for the same code, using the higher applicable Medicare rate so that all figures are conservative. Prices published without a matchable billing code are excluded rather than estimated. List prices are distinct from negotiated rates, including the arrangement pricing governed by the statute's direct-to-employer provision. To keep the focus on market-wide patterns, findings are reported in aggregate rather than by institution.
The Solomon Report is an ongoing public reporting series from Solomon Copilot that measures what public healthcare pricing data actually shows. Hospital prices and Medicare rates are public records. The Report puts them side by side.