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Tuesday July 27, 2021  |  Shawn Wiese, Director, Product Regulatory Compliance at MEDHOST

CMS Ups the Ante on Price Transparency Compliance

CMS Ups Ante Price Transparency Compliance EHR

Although the mandate has been established for over a year, the Price Transparency Rule continues to evolve.

As the rule transitions, along with updates from our team, we are making it a priority to share what we learn to so none of our customers are caught off-guard.

Price Transparency Rule Background

On November 27th, 2019 CMS released the OPPS (Outpatient Perspective Payment System) final rule, which contained requirements for hospitals to make standard charges public. Under this rule, hospitals are required to make publicly available, online, a machine-readable file of all standard charges for all items and services and a consumer-friendly list of 300 shoppable items. Price listings must contain certain information for each item or service provided by the hospital, including:

  • A service description
  • Gross charge amount
  • Payer-specific negotiated charge
  • De-identified minimum negotiated charge
  • De-identified maximum charge
  • Discounted cash price

These requirements had an effective date of Jan 1st, 2021. This past April, CMS began sending out warning letters stating the hospital had a specific timeframe in which to correct the identified non-conformance. Civil monetary penalties of $300 a day could be levied against hospitals that ignore or fail to satisfy the CMS request for corrective action.

In March of 2021, Health Affairs analysis had cited that 65 out of 100 of the nations largest hospitals were non-compliant with the transparency rule. A second study conducted by Milliman found that 32% of the included health system did not post the required files, and those that did had a wide variance in the content and presentation.

CMS is not taking the industries inattentiveness to the transparency rule lightly. On July 19, CMS made the OPPS 2022 proposed rule available for public viewing. In the rule CMS is proposing to significantly raise the monetary penalties for hospitals that have more than 30 available beds, as reported on the most recently finalized Medicare cost report.

In brief, for hospitals that have a 30 or fewer bed count, the penalty will remain the same. For larger hospitals, CMS is proposing to penalize non-conformance with the transparency at a rate of $10 per bed per day for a maximum of $5,500 a day per hospital, or $2,007, 500 per year.

Our hospital partners who have adopted the MEDHOST Price Transparency solution can be confident they are in compliance with the regulations and meet all requirements. Our solution has been designed and implemented in accordance with CMS’s Final Rule (CMS-1717-F2) and guidance provided on the CMS Hospital Price Transparency website.

If your hospital or healthcare organization is still working towards Price Transparency Rule compliance, now is the time to make the mandate a priority. For further details on how we can help you meet the Price Transparency Rule requirements, contact your MEDHOST Account Executive or please reach out to us at or call 1.800.383.6278.

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