CMS to launch first price transparency audits for 2021

CMS announced December 18 that it will begin auditing hospitals for compliance with the Hospital Price Transparency final rule in January 2021, according to an MLN Connects special edition article.

CMS will audit a sample of hospitals and will also investigate complaints of noncompliance. If a hospital is not in compliance, CMS may take the following actions:

• Warn the hospital in writing of the specific violations
• Require a corrective action plan
• Impose a civil monetary penalty and publicize the penalty on a CMS website

More information on monitoring and enforcement can be found at 45 CFR Subpart C.

Preparing to comply with the new requirements has been challenging for many organizations. According to the final rule, by January 1, 2021, most licensed hospitals will need to post their standard charges as a single machine-readable file and as a consumer-friendly listing of 300 shoppable services. The machine-readable file must include standard charges for all items and services provided by the hospital. Standard charges, as defined by CMS, include the following types of charges:

• De-identified minimum and maximum negotiated charges
• Discounted cash prices
• Gross charges
• Payer-specific negotiated rates

Revenue integrity professionals may refer to the following NAHRI resources for additional information and expert guidance:

• “Final check: Last minute tips for price transparency”
• “CMS launches Hospital Price Transparency website for hospitals and patients”
• NAHRI Pacific Northwest Regional Chapter Inaugural Meeting
• “NAHRI Professional Advocacy Committee offers guidance on CMS price transparency requirements”
• “Optimizing the revenue cycle for price transparency regulations and consumer demands” (NAHRI members only)
• “A new vision for hospital price transparency” (NAHRI members only)
• January 2020 NAHRI Quarterly Call (NAHRI members only)

See CMS’ Hospital Price Transparency website for more information and resources, including FAQs, a compliance checklist, and technical information on creating a machine-readable file and a consumer-friendly display.

Although the American Hospital Association is challenging the final rule in court and has asked President-elect Joe Biden to rescind certain requirements, organizations must still be in compliance with the final rule by January 1, 2021.

Editor’s note

Get in-depth analysis of CMS’ price transparency requirements and their impact on the industry with the on-demand version of Revenue Integrity and Reimbursement Strategies: A NAHRI Virtual Event. NAHRI Advisory Board Members Sarah L. Goodman, MBA, CHCAF, COC, CCP, FCS, CHRI; Kay Larsen, CRCR, CHRI; Valerie Rinkle, MPA, CHRI; Jugna Shah, MPH, CHRI; John Settlemyer, MBA, MHA, CPC, CHRI; and Caroline Znaniec, MBA, MS-HCA; and former CMS senior executive Marc Hartstein, MA, discuss the regulatory basis and implications of the requirements, practical tips for compliance, pricing methodologies, and strategies for communicating price information.