CMS Price Transparency Final Rule

On November 15, 2019, following an executive order from President Trump, the Centers for Medicare and Medicaid Services (CMS) finalized a comprehensive rule on healthcare price transparency. When the final rule was published, there was general industry sentiment that it would likely be halted in a superior court, given the proprietary information that is being required to be reported. However, the final rule is yet to run into significant legal resistance, and is scheduled to go into effect on January 1, 2021.

Who is impacted by the by final rule?

All hospitals.

What needs to happen by January 1, 2021?

All non-governmental hospitals are required to:

  1. Display all charges in a machine readable format on their website; and
  2. Display 300 “shoppable” services in a consumer friendly format on their website.

Both of the above need to include the following components:

  • Billing identifier (CPT/HCPCS/DRG);
  • Charge or service description;
  • Gross charge of service;
  • Payor-negotiated rates;
  • De-identified minimum and maximum payor-negotiated rates; and
  • Self-pay cash rate.

How BNN can help:

BNN can assist hospitals with compiling payor contract information, payor fee schedules and charge description master items to build the machine readable file.

CMS has mandated a list of 70 of the 300 shoppable services. BNN can assist hospitals with identifying the remaining 230 additional relevant services. In addition to chargemaster items, this will include total surgery pricing and their associated professional components (anesthesiology, surgeon, radiologist, etc., where applicable).

What happens if I do not comply?

The final rule stated that CMS will be monitoring for compliance. Hospitals that fail to comply will be assessed a $300 per day (per facility) penalty.  This penalty has the potential to amount to $109,500 per hospital, per year.

FOR MORE INFORMATION, PLEASE CONTACT THE FOLLOWING MEMBERS OF OUR HEALTHCARE ADVISORY GROUP:

Eric Wetherell, CPA: Principal and Healthcare Advisory Group Lead

Robert Gilbert, FHFMA, COC: Senior Manager

Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, investment, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.

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