NHHA recently sent member advisory to hospital chief financial officers, compliance and communications teams regarding a new Centers for Medicare and Medicaid Services (CMS) requirement that all hospitals post their standard charges as reflected in the chargemaster. 

 

CMS 2019 IPPS Final Rule Transparency Requirement

The 2019 IPPS final rule (pages 2135-2142) requires all “hospitals to make available a list of their current standard charges via the internet in a machine-readable format and to update this information at least annually, or more often as appropriate.” The rule, effective January 1, 2019, provides guidelines for an existing requirement from Section 2718(e) of the Public Health Service Act.  The rule applies to “each hospital operating within the United States.”  

NHHA Guidance

CMS is requiring hospitals to provide information for all items and services provided by the hospital based on the chargemaster, but has provided limited guidance regarding the requirement. NHHA recommends that hospitals review carefully the most recent set of Frequently Asked Questions (FAQ) released by CMS regarding the new requirements, as well as the American Hospital Association Advisory.  We understand CMS views the current requirement as an initial step and plans to expand transparency requirements in a more detailed way in future rulemaking.

NHHA does not expect additional guidance or clarification from CMS prior to the January 1,2019 effective date.  

NHHA believes that posting of standard charges as reflected in the chargemaster will provide little help to patients in determining their potential costs of care.  While the hospital chargemaster must be posted under the CMS rule, NHHA is recommending hospitals post the link to the chargemaster information near other information, such as links to other pricing and transparency tools, information advising patients of their ability to request an estimate of charges and information regarding financial assistance (also referred to as charity care).   NHHA recommends hospitals make efforts to comply with the requirements as they are currently known. 

 

Specifics of the Final Rule Requirements

The final rule requires hospitals to make available a list of their current standard charges via the internet and to update it at least annually, or more often as appropriate.  We believe via the internet generally means through a link on the hospital’s website. 

  • Standard Charges: The term “Standard Charges” is not defined in the rule, other than it refers to “items and services as reflected in the chargemaster.”  NHHA believes that the information posted should be presented in a way that reduces confusion for the patient, which might include only the description of the service and the associated charge as reflected in the chargemaster.
  • Services: The FAQ requires hospitals to include all items and services provided by the hospitals but does not address items or services that are not in the chargemaster itself. 
  • Machine Readable: According to the CMS FAQ, “machine readable format” is a format that can be imported/read into a computer system. The FAQ lists XML and CSV as examples of acceptable “machine readable format".
  • Timing of Updates: The new guidelines indicates hospitals should update the information “at least annually, or more often as appropriate”. We believe hospitals should determine whether changes to standard charges outside of a regular update schedule are significant enough to warrant an update to the posted information outside of a regular annual update.

NHHA will continue to work with the American Hospital Association and others, including CMS, to offer feedback and gain clarification on the new guidelines and other federal price transparency efforts.  We will continue to update members as additional information becomes available, however should you have any questions please feel free to contact Nick Carano, Director, Financial Policy & Reimbursement, at This email address is being protected from spambots. You need JavaScript enabled to view it. or (603) 415-4253.