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NOT IN COMPLIANCE? 8 TIPS FROM OUR DATA ANALYTICS TEAM

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:

 1. <ein>: The hospital’s employer identification number, without dashes.
 2. <hospital-name>: The hospital’s name, with no capital letters and with
    dashes between words.
 3. <standardcharges>: Write out the term “standardcharges” with no spaces or
    capital letters.
 4. [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.

Published 09/08/2021By ATL Admin
Categorized as Uncategorized


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 * What Makes Us Different
 * Meet the HDA Team

WHO WE SERVE

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   Hospital Groups
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 * Revenue Cycle Management Companies
 * Healthcare Consulting Firms
 * Health Advocates &
   Advisors

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   Hospitals
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