A recent report found that 94 percent of hospitals aren’t in compliance with the CMS’s Hospital Price Transparency final rule. Perhaps your hospital is one of them. Many of the hospitals featured in the report had published some pricing data, but did not meet all the rule’s requirements.
This left them labeled “noncompliant.”
If you’re among the 94 percent of hospitals currently not in compliance with the rule, you know that meeting all of its criteria is a highly complex endeavor. It requires not only collecting raw data but also displaying that data in a clear, comprehensive, and user-friendly way.
Hospitals can refer to the Hospital Price Transparency Requirements Quick Reference Checklists released by CMS to assist with their internal review of the final transparency rule.
In the meantime, our analytics team has been working with hospital data for quite some time now, and they’ve noticed some common reasons hospitals are technically noncompliant, even when they’ve published some of their data.
Here are eight tips to help you avoid those mistakes and oversights.
1. Publish Separate Data for Hospital Locations with Different Pricing
Perhaps your hospital system has several locations that operate under a single license. Unless every hospital has the same standard pricing for every service, you must publish a file for each location – and clearly label the location within the price list file.
Pricing that may differ from location to location includes…
- Gross charges.
- Discounted cash prices.
- Payer-specific negotiated charges.
- De-identified minimum negotiated charges.
- De-identified maximum negotiated charges.
Bottom line: Each location with unique standard charges must publish a machine-readable price transparency file. This brings us to the second tip.
2. Save Your Data File in the Proper Format
There are several minute criteria that a hospital’s transparency file must meet, and it can be easy to overlook these small details.
First, a hospital’s transparency file must be “machine-readable,” which means a computer must be able to process the information in the file.
Examples of machine-readable file formats include:
- .XML
- .JSON
- .CSV
Note that some common file formats, such as PDFs, are not machine readable. Though tools exist to extract the information in PDFs and make it available for use by application, PDFs are limited in their ability to allow for further processing of the information.
CMS recommends that hospitals save the price transparency files in .XML, .JSON, or .CSV formats.
3. Include All Data in a Single File
The next consideration for your data file is that each hospital (or hospital location) must publish a single file that contains all of the required data. Uploading multiple files or creating multiple search pages will make your hospital noncompliant.
4. Name Your Data File Correctly
Hospitals must use a very specific naming convention for their single machine-readable file. This is the format: <ein>_<hospital-name>_<standardcharges>.[json|xml|csv]. Here’s a breakdown of what each part means:
- <ein>: The hospital’s employer identification number, without dashes.
- <hospital-name>: The hospital’s name, with no capital letters and with dashes between words.
- <standardcharges>: Write out the term “standardcharges” with no spaces or capital letters.
- [json|xml|csv]: The hospital’s chosen file format.
An example file name would be: 12345_city-hospital_standardcharges.csv.
For more information, review the CMS presentation that covers the eight steps to creating a machine-readable file.
5. Display the Files Properly
In addition to formatting the machine-readable file correctly, hospitals must also meet the rule’s criteria for displaying that file. This comes with a new set of challenges.
The file must be…
- Posted publicly online, not just made available by request.
- Digitally searchable.
- “Prominent,” or easy to locate, on the hospital’s website.
- Accessible for free and without registration.
If a hospital’s file is difficult to find on its website, impossible to search digitally, or accessible only if a person creates an account or submits personally identifying information, the hospital will be considered non-compliant and subject to CMS fines.
6. Publish a User-Friendly Version
In addition to the machine-readable file, so-called shoppable services must be displayed on their own in a user-friendly way, such as in a searchable list or price estimator tool.
The CMS has identified 70 shoppable services that hospitals must include in the user-friendly format. In addition, hospitals must publish 230 additional shoppable services, for a total of 300. If the hospital does not offer some of the 70 required services, this must be clearly indicated in the tool.
For more information about how to meet the requirements for the consumer-friendly display of the data, review the 10 steps CMS posted here.
7. List Negotiated Prices by Payer and Plan
Hospitals are required to disclose payer-specific negotiated charges by both payer and plan. Of the 94 percent of hospitals that were found noncompliant with the transparency rule, 80 percent did not clearly match published prices to a payer and / or plan.
To find the payer-specific negotiated charges, hospitals will need to review their third-party payer contracts and rate sheets.
Keep this important point in mind: this information must be current and specific. Hospitals are not allowed to create or use past averages or aggregated charges.
8. Update Data Annually
Finally, once a hospital uploads its compliant transparency file and shoppable services display, it must keep the data current. Hospitals are required to update the data at least once each year and indicate in the file that the pricing was updated.
Let Healthcare Data Analytics Help
Are you wondering whether your hospital is fully compliant with the price transparency rule? Don’t hesitate to get in touch. We are monitoring data and evaluating hospitals with our compliance dashboard, which is based on CMS guidelines.
At your request, we will provide you with your compliance score (out of 100 percent).
And if you need some help getting your hospital in compliance, whether to avoid penalties or reputational risk, just let us know. We offer a simple program to help you reach full compliance, and we take care of the heavy lifting. Contact us to learn more.
Regardless of your current compliance score, we can also help you understand how your prices compare with those of your competitors. For more information, visit our analytics page or ask us for a demo of how our analytics tools work.