Upon release of the 2024 Outpatient Prospective Payment System (OPPS) Final Rule in November, CMS finalized a number of changes to existing hospital price transparency regulations. Key changes hospitals should be aware of include:
Timeline
CMS’ Machine-Readable File (MRF) template is publicly available, although there will be a phased implementation timeline. While the rule is effective January 1, 2024, CMS will allow hospitals until July 1, 2024 to adopt the CMS-required template and encode standard charge information for a subset of data elements. There also are a number of new required data elements, which must be encoded by January 1, 2025.
MRF Template
CMS will require all hospitals to adopt a standard MRF template in which their charge information will be displayed. CMS has released guidance on data specifications and a data dictionary as well. The templates have been made available in several formats—a “tall” CSV file, a “wide” CSV file, and a JSON Schema. Hospitals must encode their standard charges in one of these new formats by July 1, 2024.
New & Revised MRF Fields
CMS has released several new and revised requirements for the data to be encoded in MRFs. Unless otherwise specified, these elements are required as of July 1, 2024:
- General guidelines.
- CMS has defined the accepted data types and—in some cases—valid values for each encoded field within the CSV and JSON templates.
- Hospitals may include additional optional information in CMS-defined optional data elements or hospital-created data elements.
- File information. The following data elements must be included in the template file:
- Hospital name (legal business name)
- Date file was last updated
- CMS template version
- Hospital location(s)
- Hospital addresses
- Hospital licensure information
- Affirmation statement. CMS has included a required affirmation statement in the templates to which the hospital must answer yes or no.
- Item & Service information. CMS has added the following new fields, to be required effective January 1, 2025:
- Drug unit of measurement
- Drug type of measurement
- Coding Information. CMS will require hospitals to define the code type for each code included. Effective January 1, 2025, modifiers also must be included.
- Standard charges.
- CMS has expanded the information required for Payer-Specific Negotiated Charges to include three fields with distinct data types:
- Dollar Amount
- Percentage
- Algorithm
- CMS also is adding a new required field effective January 1, 2025—Consumer-friendly expected allowed amount—which is defined as “the average dollar amount that the hospital estimates it will be paid by a third-party payer for an item or service” to be included in cases where the negotiated charge is a percentage or algorithm.
- Lastly, CMS will require hospitals to define the methodology for each standard charge from a CMS-prescribed list.
- CMS has expanded the information required for Payer-Specific Negotiated Charges to include three fields with distinct data types:
Website Location Requirement
To support accessibility of the information and compliance enforcement, CMS will begin requiring “hospitals to place a ‘footer’ at the bottom of the hospital’s homepage that links to the webpage that includes the MRF and requiring hospitals to ensure that a .txt file is included in the root folder of the publicly available website chosen by the hospital for posting its MRF. The .txt file must identify the URL for both the MRF and the webpage that contains the link to the MRF.”
Compliance & Penalties
CMS has strengthened its enforcement capabilities with the following potential actions:
- CMS may require hospitals to certify the accuracy and completeness of their MRFs.
- CMS may require hospitals to acknowledge receipt of warning notice.
- CMS may work directly with the parent system to achieve hospital compliance.
- CMS may publicize compliance information.
Consumer-Shoppable Display
No changes were made to prior requirements.
The Final Rule published on November 22, 2023 can be found online.
FORVIS is available to support hospitals in updating their Price Transparency files to assist with maintaining compliance with CMS. If you have questions or need assistance, please reach out to a professional at FORVIS.