Texas has no hospital price benchmark law. This report measures the largest hospital market in the series against the strictest line any state has enacted.
This is the share of more than 261,000 benchmarkable list prices published by major hospital systems operating in Texas that currently sit above 260% of the corresponding Medicare rate. The line Indiana wrote into law.
Indiana's 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. It is the most direct hospital pricing benchmark enacted in the country. Texas has no equivalent. No Texas statute draws a line against Medicare, and no Texas hospital is required to price against one.
What Texas does require is disclosure. Senate Bill 1137 passed unanimously in 2021, making Texas one of the first states to write the federal price transparency rule into its own law, with graduated daily penalties enforced by the state's Health and Human Services Commission. Texas hospitals must publish their prices. Nothing in Texas law speaks to what those prices may be. That combination, full disclosure and no line, makes Texas the cleanest measurement in this series so far.
The Solomon Report measured it using the identical instrument as Reports No. 1 and No. 2. Across 158 hospital facilities in 22 major systems operating in Texas, the largest population of prices this series has examined, the answer is further from the line than either state measured before.
Report No. 1 measured Indiana's published hospital prices against the 260% of Medicare benchmark in Indiana's own law and found 86.8% above the line. Report No. 2 applied the same line to Ohio and found 93.2%. This report applies it to Texas, not because Texas is bound by it, but because it is the only price benchmark an American legislature has enacted with this level of directness. A common yardstick is what is needed to make states comparable at all.
Price benchmarks tied to Medicare are spreading. Indiana's employer contracting requirement has applied to its largest systems since September 2025 and reaches independent hospitals on September 1, 2026, weeks after this report's filing. Oregon has operated a cap on what its state employee plans pay hospitals, with documented savings exceeding $100 million in its first two years. Vermont has adopted employer-plan price limits of its own. Whether Texas ever draws such a line is a question for Texans. What this report establishes is where the published prices of the largest uncapped hospital market in the series stand today relative to the strictest line that exists.
Across 158 facilities in 22 major hospital systems operating in Texas, 94.1% of the 261,779 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. By the identical computation, Indiana's share was 86.8% and Ohio's was 93.2%.
The finding is not sensitive to where the line is drawn. Moving the threshold from 200% of Medicare to 300% changes the answer by about four points (96.3% of prices exceed 200% of Medicare, and 92.2% exceed 300%). At a threshold forty points more permissive than the one Indiana enacted, more than nine in ten Texas list prices still clear it.
The finding is not driven by any single system. All 22 systems measured land between 64.1% and 99.4% of their benchmarkable prices above the line. Twenty-two separate organizations, from academic medical centers to for-profit chains to public safety-net systems, telling one story.
Austin offers the closest look this series has taken at a single market. Across all 23 measured facilities in the Austin area, 95.7% of 45,832 benchmarkable list prices exceed the 260% line, a share higher than the state as a whole. And within that one metro, hospitals publish prices for identical billing codes that sit extremely far apart:
| Identical service, Austin-area facilities | Facilities | Lowest | Highest |
|---|---|---|---|
| Cardiopulmonary exercise test (CPT 94621) | 19 | $569 | $22,241 |
| Catheter placement, vena cava (CPT 36010) | 21 | $322 | $12,805 |
| Endovascular stroke treatment (CPT 61645) | 12 | $4,674 | $137,826 |
Each row is one billing code, priced by hospitals in one metropolitan area, drawn from their own published files. A diagnostic exercise test spans a 39-fold range. Emergency stroke treatment, a service no patient could ever be in a position to shop for, spans 29-fold.
A published list price above 260% of Medicare violates no Texas law, because Texas has drawn no such line. It would also not violate Indiana's benchmark HEA 1004. This report makes no compliance determination about any hospital anywhere. It measures distance, not violation.
What the finding does establish is the starting point. If Texas, or any state, ever considers a benchmark of its own, the adjustment implied is not marginal. The gap between the prices Texas hospitals publish today and the strictest enacted standard is the dominant feature of the data, and it is widest in the series to date.
This measurement required no subpoena, no special access, and no cooperation from any hospital. Texas law already compels the disclosure. Medicare's rates are public record.
Three states, one instrument. Indiana, with the strictest benchmark law in the country, publishes list prices that exceed its own line in 86.8% of benchmarkable cases. Ohio, with no benchmark law, exceeds it in 93.2%. Texas, with no benchmark law and the largest population of prices this series has measured, exceeds it in 94.1%. Each state examined has stood further from the line than the last, and the sample has grown with every report: 108,355 benchmarkable prices in Indiana, 192,668 in Ohio, 261,779 in Texas. Whatever explains the differences among states, the direction of the series so far is consistent, and it is away from the line.
The Solomon Report intends to keep measuring.
Solomon Report findings are computed from hospitals' federally and state 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: of 543,591 published prices at the measured Texas facilities, 261,779 could be directly benchmarked and constitute the population reported here. List prices are distinct from negotiated rates, including pricing arrangements governed by state benchmark statutes. This report uses the identical computation as Reports No. 1 and No. 2, both of which were re-run and reproduced exactly at the time of this analysis. The finding is robust to conservative restriction: limiting the population to prices between one tenth and one hundred times the corresponding Medicare rate yields 94.0% on 253,698 prices. Quoted per-code examples are drawn from Austin-area facilities and were selected to avoid codes whose published figures reflect per-unit quantities or device-bundling differences rather than facility pricing. 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.