10 Common Problems with Price Transparency Data

The Hospital Price Transparency Rule represents an important step toward fairer and more transparent pricing in the American healthcare system.

More than seven months after this rule officially took effect, a recent survey of 1000 providers in 27 states found that over two-thirds of those hospitals were far from meeting the rule’s requirements, but this is only a partial picture. Within our current database, we’d estimate that only about eight percent of the over 5300 hospitals listed are currently in compliance.

But what does noncompliance look like?

Most can be categorized as one of two types of common issues we see with a hospital’s price transparency data:

  • Issues with the format in which hospitals and groups are releasing this data
  • Issues with the data points included in published files

To break this down even further, our team of hospital pricing experts and data analysts compiled this list of 10 issues, some of which could be attributed to the ambiguity of the regulations the Centers for Medicare & Medicaid Services (CMS) has released to date.

Issues with How Hospitals Release Their Price Transparency Data

1. A Total Lack of Published Hospital Price Transparency Data

While many hospitals are currently noncompliant with one or two items on the CMS compliance checklist, many haven’t released their Price Transparency data at all. 

Of the over 5,300 hospitals and groups listed in our database today, 35 percent have yet to publish their Price Transparency data. Given that processing and posting this data is currently a fairly manual task, it’s easy to see why some institutions have gone this route, but this is still a striking number.

To get a better understanding of why, we took a closer look at who was publishing hospital pricing data. The data showed that the largest and most profitable hospitals and groups might have deemed it preferable to pay a $300 per day fine than release their Price Transparency data.

From this, we might infer two things: either they don’t want to disclose the data, or perhaps the penalty for noncompliance simply isn’t yet high enough.

Whatever the reason, following President Biden’s recent announcement that the fines for noncompliance will be increasing, this approach may soon hold less appeal.

2. File Formats That Are Not Machine Readable

One of the easiest boxes to check is one that is all too often neglected. Of the files we’ve located, 20 percent are not machine readable.

This is often because hospitals publish file extensions or formats that simply aren’t machine readable, including PDFs and JPEGs. CMS’s regs are clear – the files must be machine readable.

3. Tabbed Files That Are Difficult to Interpret (For Machines and Humans)

Some institutions publish a single digital file that consists of separate tabs for different hospitals or payers.

This format is difficult to read and requires a great deal of time to interpret. For consumers, this format also poses a challenge: it can be difficult to locate comparable codes and services between tabs.

Common Issues within Hospital Pricing Data

4. Variations in Published Price and Payer Names

Hospitals often publish prices and payer names in different ways.

For example, sometimes hospitals publish the insurance company name and sometimes they publish the insurance company name and plan name. Again, this lack of consistency creates challenges for comparative analyses.

5. Negotiated Rates Displayed as a Range of Prices

This may seem like a variation on a theme, but negotiated rates are often shown as a range of prices (e.g. $250-$350). This makes it difficult to identify the exact value negotiated for a particular procedure at the hospital.

6. Negotiated Rates for Medicare Payer Plans Reflected as a Percentage of Another Price

One of the most common and challenging issues we see in Price Transparency Data is related to the inclusion of negotiated rates for Medicare payer plans. Because of the way these rates are negotiated, hospitals often list them as a percentage of another price rather than as a straight price.

Table A

For example, Chart A shows the negotiated rates for an MRI scan of the brain at Gillette Children’s Specialty Hospital. The price for BCBS Medicare (1) is shown to be “105% Medicare FFS.”

When it comes to cleaning and aggregating data, our team typically identifies Medicare and Medicaid payers, then strips them out of the data set, as these throw off median pricing.

7. Inconsistent Codes

While many hospitals use common codes, like CPT and HCPCS, many opt to use their own internal codes, which makes prices difficult to compare. Others include common codes but attach departmental codes or other components to the core identifiers.

For our team to use this data, it takes extra time and effort to pare those complex codes down to the five digits that the most common code types use, both numeric or alphanumeric.

8. No Codes Included in the Hospital Price Transparency Data File

Too often, hospitals publish machine-readable files that simply include a plain text description of the service provided and the price. Our data analysts report that this issue appears in 13 percent of the files we’ve processed to date.

Table 2

Table B

Without a code, payer, or any of the five price types that the CMS requires, these files are of little use for comparisons and require a great deal of manual work to analyze.

9. Files with Multiple Service Descriptions for the Same CPT or HCPCS Procedure

When Price Transparency files include multiple service descriptions for the same CPT or HCPCS procedures, it can be difficult to determine which is the most accurate negotiated rate for that procedure at that hospital. 

Table C

For example, Table C shows the negotiated rates for a mammography by AMMPO Health at Abbott Northwestern Hospital. There are seven different service descriptions with prices ranging from $262 to $419.

In this type of situation, when there are multiple prices for several payer-plans, it’s unclear whether each record represents an individual price, or if an aggregate function (e.g. average or sum) should be applied to show the most accurate negotiated rate at that hospital.

10. Columns Display the Location Where the Service Was Provided

We often see price transparency files that display the location of the service provided (e.g. Emergency Department or Cardiovascular Lab) as columns rather than payer-plans prices.

Table D

As Table D demonstrates, this renders even machine-readable files challenging to parse and makes each code difficult to include in our comparative analysis.

Better Price Transparency Data Compliance Is Coming

The rollout of the Price Transparency Rule in the midst of this pandemic has, understandably, been slow. But that doesn’t mean that the CMS isn’t monitoring the way hospitals and groups are publishing or neglecting to publish their data.

The most fundamental requirements for compliance with the Hospital Price Transparency Rules include the formatting and contents of the files being published. As more providers work to become compliant, Healthcare Data Analytics will continue to monitor their publications and analyze their data, as it becomes available.

If you need assistance properly presenting your Price Transparency data or you’d like our team to assess whether your published data complies with the current rule, we’ll be happy to assist you. We’re currently providing compliance assessments at no charge – don’t hesitate to contact us with any questions about Price Transparency Rule compliance today.