Is your hospital ready for the 2024 price transparency mandate? Use our checklist to prepare.

Hospitals face multiple price transparency deadlines for the coming year that will bring new, stricter requirements and stepped-up compliance enforcement measures. As part of The Craneware Group’s commitment to helping our hospital and health system stakeholders, we offer a handy checklist below to help your teams make sure you’re prepared.

The new Jan. 1, 2024 requirements are outlined in Medicare’s 2024 Hospital Outpatient Prospective Payment System (OPPS) final rule. Price transparency itself is part of the government’s efforts to promote a “patient-driven” healthcare system and goes back to 2021, when CMS began requiring hospitals to post their standard charges via machine-readable files (MRF) and a consumer-friendly display of at least 300 shoppable services.

Starting Jan. 1, 2024, hospitals must demonstrate a “good faith effort” that the standard charges in the MRF are “true, accurate, and complete.” They must also ensure that links to the MRF appear in a .txt file in the hospital’s root folder and in a footer on the hospital website’s homepage.

This is likely in response to CMS having a hard time finding MRFs on hospital websites. By automating it with .txt files, it will be much more helpful for the researchers and payors to retrieve these files. CMS has been clear that the intention of the MRFs is not to help patients looking for pricing information — that’s the role of price estimator tools and shoppable services lists — but to stimulate market competition. So, you should understand that data will be collected by many entities, especially health plans who may use it to negotiate for lower reimbursement rates with hospitals.

The next deadline is July 1, 2024, when all hospitals must conform to the CMS machine readable file template — either a CSV “tall” or “wide” format or JSON schema — available here. CMS announced a substantial change incorporating significant new data elements such as additional hospital header information and payor contracting details that will need to be included in the mandated V2.0 template. Hospitals must also include affirmation language in their template attesting that the information in the MRF is again “true, accurate, and complete.”

Looking ahead to Jan. 1, 2025, there are requirements to include estimated allowed amount, which is the average amount the hospital has received from a third-party payor for an item or service, drug unit and type of measurement, and any modifiers and descriptions of them and how it could change the standard charge.

Hospitals that don’t comply are subject to written warnings requesting a corrective action plan, plus a civil monetary penalty if the former two points are not satisfied. CMS says it can also publicize a hospital’s penalties on its website — a “naughty list,” as we call it. Hospitals must also acknowledge in writing when they have received a warning notice about being out of compliance.

With that said, here’s a checklist we put together after extensively studying the 2024 OPPS final rule.

2024 price transparency prep checklist

  • Continue to remain compliant under the current CY 2023 OPPS final rule. CMS has found that as of 2022, only 70% of the hospitals it reviewed were in compliance with existing mandates. CMS will continue to audit hospitals. Use this time to understand what compliance looks like from now to July 1, 2024.
  • Make a good faith effort. Jan. 1, 2024 is the deadline to ensure that standard charges information in the MRF is true, accurate, and complete.
  • Start discussing website changes needed for Jan. 1, 2024 with your IT departments:
    • You must include a .txt file in the root folder to point to those pages and MRF downloads. It should include the:
      • Hospital location and name that corresponds to the MRF
      • Source page URL that hosts it
      • Direct link to the MRF
      • Hospital point-of-contact information
    • You must have a link in the footer on your homepage labeled “Price Transparency”
  • Starting Jan. 2, 2024, develop a plan for updating your current MRF for July 1, 2024:
    • How to include the July 1, 2024, data elements
    • Decide on CMS Format (CSV Wide, CSV Tall or JSON schema)
    • Consider how to include Jan. 1, 2025 data elements to reduce rework:
      • Expected Allowed Amount (How will you average payor plan remittance data to calculate?)
      • Include formulary data for drug units and type of measurement
      • Report modifiers and their impacts on price
  • On Jan. 1, 2024, validate that the changes are made:
    • Check each hospital website for a .txt file. Example: '"
    • Check each hospital’s website footer

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