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New Hospital Price Transparency Requirements

The NEW, FINAL rule from CMS is out. The Hospital Price Transparency Fact Sheet is HERE. The takeaways? Read on!

Effective January 1, 2024

Healthcare providers, mark your calendars and prepare your teams—significant updates to the Hospital Price Transparency regulations are set to take effect at the start of 2024. Here’s what you need to know and how to act:

Standardize Your Data: CMS has established a standardized template for the Hospital Price Transparency machine-readable file (MRF). You must adapt your charge information to fit either a CSV “wide” format, a CSV “tall” format, or a JSON schema as per CMS specifications.
Action: Review the sample templates on the CMS website and start converting your data accordingly.
Ensure Accessibility: A footer link to your MRF must be present on your hospital’s homepage. Moreover, a .txt file with the URL for the MRF and the page linking to it must reside in the root folder of your website.
Action: Work with your IT department to implement these website updates for easy navigation and compliance.
Affirm Accuracy: Each hospital is required to affirm that the data in the MRF is complete and accurate.
Action: Develop a verification process to ensure the integrity of your data before it is published.
Prepare for Enforcement: The CMS has enhanced its enforcement measures, which may include requiring certifications of data accuracy from hospital officials and publicizing noncompliance on the CMS website.
Action: Establish internal compliance checks and prepare to respond promptly to any CMS enforcement actions.
Phased Implementation Timeline: While the effective date is January 1, 2024, there are staggered compliance dates for some requirements.
Action: Stay informed of specific compliance dates for new requirements and begin enforcing them as they become applicable.

Immediate Steps for Providers:

Audit Current Compliance: Evaluate your current price transparency measures against the new CMS regulations.

Train Staff: Ensure that key personnel are trained on the new requirements and the importance of compliance.

Update Procedures: Revise your hospital’s standard charge posting procedures to align with the CMS template and data specifications.

Monitor CMS Communications: Regularly check CMS updates for any changes or additional guidance on compliance.

Long-Term Strategy:

Invest in Technology: Consider technological solutions that can automate the generation and updating of the MRF to minimize errors and streamline the process.

Focus on Data Management: Dedicate resources to maintain the accuracy and completeness of your pricing data.

Engage with Leadership: Keep hospital and health system leadership informed of the transparency requirements and involved in compliance efforts.

By taking proactive steps now, you can ensure a smooth transition to the new price transparency landscape, uphold the trust of your patients, and avoid potential penalties.