The System Sets the Price

Under the federal Hospital Price Transparency rule, Wisconsin's hospitals are required to publish a list price, known in the rule as the gross charge, for every item and service they provide. This report measures what they actually publish, against the Solomon Standard, 260% of Medicare, under v1.1.

Of 429,884 list prices that could be matched to a 2026 Medicare rate, 383,147 sit above the Solomon Standard. That is 89.1%. At 200% of Medicare the share is 92.8%. Move the line up to 300% of Medicare and 85.9% of prices are still above it. Excluding extreme prices, below a tenth or above 100 times Medicare, leaves the figure at 89.1%. Measuring only hospitals with their own Medicare provider number moves it to 89.3%. Leaving out four files that are near copies of other files moves it to 89.0%. Laboratory tests, measured separately under v1.1, sit above the Solomon Standard 92.0% of the time.

Wisconsin is the largest state in the series by benchmarkable prices.

What sets Wisconsin apart is who owns its rural hospitals. Its 57 critical access hospitals carry 49.0% of the state's benchmarkable prices. In Idaho, critical access hospitals priced well below the rest of the state. In Wisconsin, those in the three largest systems publish their system's price list, and the rest price well below it.

All eleven states are shown under the Solomon Standard v1.1. Reports No. 1 through 10 were published under version 1 and stand as measured; their v1.1 figures are on the methodology page. Before any Wisconsin figure was computed, the ten earlier states' v1.1 figures were reproduced exactly on the same table.

Sixteen critical access hospitals owned by three systems carry 69.7% of all critical access prices in the state. At their rural hospitals, these systems publish the same price list they use everywhere else. The other 41 critical access hospitals, 20 of them independent and 21 in smaller systems, sit 9 points below the state's larger hospitals.

The clearest case is ThedaCare. Its five critical access hospitals in Berlin, New London, Shawano, Waupaca and Wild Rose, and its two regional medical centers in Appleton and Neenah measure identically: at each of the seven, 12,359 of 12,862 benchmarkable prices sit above the Solomon Standard, 96.1%. A rural hospital priced by a large system looks like the system, not like its neighbors.

Both groups are measured the same way, by comparing each hospital's list price to the Medicare rate for the same service. For critical access hospitals, that rate is a reference point rather than what Medicare actually pays them. Medicare pays these hospitals based on their reported costs, not its fee schedule.

The 74 other price files are 60 hospitals paid under Medicare's national payment systems, the two Children's Wisconsin hospitals, two new hospitals without their own Medicare provider number, and 10 campuses that publish their own files; see Methodology. The 41-hospital figure is derived by subtracting the three systems' measured figures from the critical access total; the systems do not overlap.

Aspirus is the largest contributor to this report, with 28.1% of every benchmarkable price in the state; Froedtert ThedaCare is next, with 23.6%. Together they carry more than half of Wisconsin's prices, and both sit above 93%.

Marshfield Clinic Health System sits at 67.0%, the lowest of the large systems and 28 points below Froedtert ThedaCare. As in Idaho and Florida, the price moves with the owner.

Systems carrying at least 1% of the state's benchmarkable prices are shown. Price files include campuses that publish their own files. Among hospitals with at least 1,000 benchmarkable prices, the share above the Solomon Standard runs from 57.2% at Edgerton Hospital and Health Services, an independent critical access hospital, to 96.1% at the seven ThedaCare hospitals. Marshfield's hospitals fill eight of the ten lowest places, from 66.1% to 67.4%.

In 2026, Medicare pays $106.55 for a CT scan of the head without contrast (CPT 70450), the national rate used under Solomon Standard v1.1. One hundred seventeen of Wisconsin's 121 measured hospitals publish a list price for it. Each hospital's price here is its highest full-service list price for the code. The median is $2,329.

The spread between the lowest and highest hospital is 7.3 to 1. After Oconto, the next lowest price is $1,020, published by seven Marshfield hospitals from one price list. All 13 Aurora hospitals and Aurora's four campuses, 17 price files in all, publish the same $2,940. As in every state in the series, a shared price is one decision, not several.

Prices are each hospital's highest full-service list price for the code, excluding component-only lines (professional or technical only) and $1.00 placeholders. Four hospitals publish no list price for 70450: Gundersen Lutheran Medical Center, Mile Bluff Medical Center and Watertown Regional Medical Center publish negotiated rates only on it, and St. Croix Regional Medical Center publishes it only as a professional-only line, which this method excludes. The same four publish no list price for 76700 or 74177. A hospital is named only where it sets the state's floor or ceiling, or where it shares a price list.

For inpatient care, hospitals publish the rates they have negotiated with each insurer for each diagnosis-related group, measured here against each hospital's own wage-adjusted Medicare payment. Sixty-three Wisconsin price files are measured this way: 56 hospitals with their own Medicare inpatient rate and 7 campuses priced at their parent hospital's rate. Exclusions are listed under Limits.

At the ceiling, Wisconsin's hospitals charge some insurer a median of 3.56 times Medicare for an inpatient stay, and 86.2% of those ceiling rates sit above the Solomon Standard. That is below Florida's 4.37x and New Jersey's 3.79x, and above Idaho's 3.10x and North Carolina's 3.04x. By hospital, the median ceiling runs from 1.45x at Ascension St. Francis Hospital to 5.56x at Froedtert Hospital.

Wisconsin's hospitals publish usable inpatient dollar rates for three Medicare Advantage insurers in 24 or more of the 48 files that list any Medicare Advantage plan on a diagnosis group: Anthem Blue Cross and Blue Shield (32 files), UnitedHealthcare (30) and Humana (25). Each insurer's median falls between 1.15 and 1.19 times Medicare, however the files are counted. None of the three is owned by a hospital system. Thirty commercial payer names publish usable inpatient rates in Wisconsin's files. Counting Aurora's 17 price files, which share one list, as one, none appears at more than 12 hospitals, too few for a statewide insurer comparison.

At the floor, the lowest negotiated rate per stay has a median of 1.19 times Medicare across 57 hospitals, ranging from 1.00 to 2.49, a band that includes SCAN's 1.12. SCAN is the California Medicare Advantage plan used as the control in this series since Report No. 5. Six more hospitals have floors below Medicare: Sauk Prairie Hospital at 0.56 times, four SSM Health hospitals from 0.84 to 0.93, and Bellin Memorial Hospital at 0.97. As in Florida and Idaho, they are set aside from the floor figure rather than pooled with it.

The payer names behind the floor were read from the hospitals' own files and checked against the published minimum on every diagnosis group. On 57.7% of diagnosis groups, a Medicare Advantage plan sets the floor, alone or tied with a veterans' plan; it holds the floor on most diagnosis groups at 37 of 63 hospitals. No hospital's floor is set mainly by traditional Medicare or by Medicaid.

Aurora Health Care is the exception. Its 17 files publish no Medicare Advantage, Medicaid, veterans' or Medicare rates on any inpatient stay; every inpatient rate in them belongs to a commercial or employer plan. Aurora's floors therefore sit far higher, from 1.84 to 2.49 times Medicare, and Aurora West Allis Medical Center has the highest floor in the state.

Some published minimums are not prices for a stay. Two HSHS hospitals in Green Bay publish a $500 estimate column on nearly every diagnosis group. The lowest rate and the highest rate belong to different insurers at the same hospital. Which one a plan pays depends on its contract.

Limits. The inpatient basis covers 63 of 131 files. The 57 critical access hospitals are outside Medicare's inpatient payment system. The three HSHS hospitals publish no payer dollar amount on any diagnosis group. Children's Wisconsin's two hospitals (Milwaukee and Fox Valley) are included in the outpatient measure but not the inpatient measure. Medicare pays children's hospitals outside its inpatient prospective payment system, so there is no Medicare inpatient base rate to compare their DRG prices against. ThedaCare Regional Medical Center-Neenah publishes no inpatient rates.

Every hospital in this report has attested under federal rule that its price file is accurate and complete. The files were read as published.

• A file cut off at a spreadsheet limit. Ascension All Saints Hospital in Racine publishes one file. It ends at 1,048,576 lines, the maximum row count of an Excel worksheet, and contains 208 lines with a CPT code and no inpatient diagnosis codes. It was not measured.
• No inpatient rates. ThedaCare Regional Medical Center-Neenah, a full acute-care hospital, publishes a file with no inpatient rates. The most recent inpatient prices ThedaCare published for Neenah are dated January 2022 and fall outside this report's 18-month window.
• No payer dollar amounts on inpatient stays. HSHS St. Mary's and St. Vincent in Green Bay and HSHS St. Nicholas in Sheboygan publish their inpatient rates as percentages, formulas or an estimate column. No payer dollar amount appears across 56,492 diagnosis-group lines in the three files.
• Non-standard codes. Watertown Regional Medical Center's file publishes most of its gross charges on lines with non-standard codes (a leading zero before the CPT or HCPCS code); those lines were not matched to Medicare benchmarks. Its standard-coded lines with a gross charge, almost all drugs and supplies, were measured as usual.
• Cash prices. 116 of 121 hospitals publish a cash price. The five that do not are critical access hospitals. At four of them, AdventHealth Durand, Crossing Rivers, Vernon Memorial and Cumberland Memorial, the cash column is identical to the list price on every row, so it was not used. Western Wisconsin Health publishes no cash price on any line.
• The device catalogue. Aspirus's files repeat a catalogue of 121,677 device lines in each hospital's file. Medicare's fee schedule has no rate for these codes, so none of them enters this report's measurement. The catalogue is in the files; it does not move the number.
• Shared price lists and copied files. Several systems publish one price list across their hospitals, and five campus files were exact copies of their parent hospital's file. Shared lists are counted as published, as the series has done since Report No. 7; exact copies are counted once.

In Wisconsin, the clearest predictor of a hospital's prices is not its size or its town. It is its owner.

Wisconsin law sets no cap on hospital prices and no Medicare-based price for any purchaser, including the state employee plan. It does require disclosure. Under a 2009 law, every hospital must give any health care consumer who asks a document listing its median charge, the average Medicare payment and the average private-insurer payment for 75 common inpatient stays and 75 outpatient surgeries (Wis. Stat. s. 146.903). Since March 22, 2026, a second law (s. 146.904) requires that if the federal price transparency rule is ever repealed with no replacement, the state health department adopt and enforce the same rule.

For employers, the files show that Wisconsin's hospitals already accept rates near Medicare for inpatient care from some payers, for the same stays they price far higher for others. At one hospital, an employer cooperative's published rate is below Medicare. What an employer's plan pays depends on what it negotiates, not on what hospitals can accept.

The question this report cannot answer is why hospitals in the same state, publishing under the same federal rule, price so differently. The files only show that they do.