Hospital Price Transparency: Have You Reached Full Compliance?
CMS is stepping up its efforts to ensure that every qualified hospital complies with the hospital price transparency requirements. Through 2022, CMS has reported that 70% of hospitals are in compliance, which represents a 43% increase in compliance when compared to 2021. All hospitals, with the exception of federally owned or operated hospitals (for example, Indian Health Program, U.S. Department of Veterans Affairs, U.S. Department of Defense) are required to comply with the price transparency requirements.
Three avenues CMS utilizes for monitoring and assessing a hospital’s compliance with the price transparency requirements include: evaluating complaints made by the public, CMS review of individuals’ or entities analysis of hospital non-compliance, and internal audits of hospital websites.Through April 2023 CMS has issued 730 warning notices and 269 requests for a corrective action plan (CAP). So far only four hospitals have been assessed a civil monetary penalty (CMP) for non-compliance. The penalties range from a low of $102,660 to a high of $883,180. Can you afford this if your hospital is non-compliant?
CMS hospital price transparency requirements were authorized by section 2781(e) of the Public Health Service Act and became effective on January 1, 2021. Hospitals were required to publicly post a machine-readable file that contains a wide range of rate information and a consumer-friendly display of at least 300 shoppable services.
So what does this mean? If your hospital is complying with the price transparency requirements and has survived the Comprehensive Review Process, then you can breath easy as long as you continue to maintain compliance. If not, it is time to assess how your hospital can reach full compliance.
The are several automated tools on the marketplace that can assist your hospital to reach full compliance with the requirements. For example, MCAnalyTX's All-Payor System offers a robust platform in partnership with Oracle that utilizes contract and patient claim data to arrive at a compliant price transparency solution.
For more information, please reach out to:
Richard T. (Terry) Lang, CPA, FHFMA- Managing Pricipal
