In concert: A team-based approach to price transparency compliance

Preparing to comply with CMS’ Hospital Price Transparency final rule was no mean feat for revenue integrity professionals. An already significant lift was made heavier by the COVID-19 pandemic. With workplaces disrupted and resources stretched to the breaking point, revenue integrity professionals needed to react quickly and revise plans to help their organizations meet the January 1 compliance deadline.

A head start, a well-developed plan, and plenty of teamwork ensured Beaumont Health in Southfield, Michigan, was able to stay on track, says Meagen Windler, CHRI, corporate director, charge description master (CDM) at Beaumont.

“We were able to work quickly and adapt. But we didn’t wait until the last minute to start, we knew what needed to happen and those conversations had been going on throughout the year,” Windler says. “Like any other organization, everyone is feeling the financial impact of COVID. We just have to roll up our sleeves, and sometimes we just have to take on things that we maybe normally wouldn’t take on. That’s part of being with an organization and working with individuals who are willing and open to collaborate with each other.”

Windler’s position made her the natural pick to lead Beaumont’s price transparency compliance efforts. She assembled an interdepartmental team, the members of which were carefully selected to represent key stakeholders and critical perspectives. Her team included representatives from compliance, legal, finance, IT, CDM, and managed care, as well as pharmacy, material management, Beaumont’s medical group, and marketing. Windler knew she needed that breadth of insight and experience to ensure that the organization was fully cognizant of all the implications of the price transparency rule and its effects on the organization.

Compliance and legal, for example, helped analyze the rule and how it must be applied, she explains. Beaumont also called on outside council to ensure that it had the appropriate disclaimers in place and that price information was compliantly displayed on the facility’s website.

Managed care staff were key to ensuring that third-party negotiated rates were accurate, Windler says. On the facility side of the organization, negotiated rates are included in Epic files, but these files needed to be carefully reviewed and compared to payers’ contracts to ensure they were correct.

“The Epic files were not as user-friendly, or did not produce the level of information, that many would have expected,” Windler says. “It did require quite a bit of manual review and evaluation to ensure the accuracy of the information that had been provided from the system. And just making sure that you have all your contracts in the system so you can track that information.”

Representatives from materials management and pharmacy were called in to review prices for pharmaceuticals and certain supplies. Similarly, physicians from Beaumont’s medical group were asked to review professional fees prices, adding yet another accuracy check, Windler says.

Even prior to the rule, Beaumont used Epic’s built-in price estimator tool, Windler says. The tool was reviewed and expanded to ensure it met CMS’ requirements. The tool is used extensively by revenue cycle staff to provide estimates to patients, and these individuals were included in Windler’s team to offer insight into how the tool works and to add services and prices. They’ll also be instrumental in efforts to further develop the tool, she adds.

Finally, Windler brought in staff from the marketing department to ensure the organization was crafting a clear, unified message.

“Our marketing group was very hands on, making sure that for the procedures that were noted in the price estimator tool there was a clear description,” Windler says. “Marketing also helped us make sure everything was in line on our website, that the links all worked, and everybody was on the same page as far as what the message was and information that was going to be made public for price transparency.”

Windler credits a regular meeting and update schedule with keeping the project on track and individual contributors informed. It also allowed her to keep the C-suite looped in on their progress.

The larger group, including market liaisons and C-suite executives, participated in scheduled updates. Windler kept regular meetings on the calendar for the smaller groups that were tasked with specific aspects of the project, such as reviewing negotiated rates. Additional individuals were notified that they would be included on an ad hoc basis, she adds.

“I think the best way to try to keep things on track is to have a set schedule. Everybody thankfully was very receptive to that and attended,” Windler says. “So if they were seeing things that we needed to follow up on or review or people had questions, we were able to work with each of those individuals to ensure that part of it was addressed prior to the next meeting.”