The 2024 Medicare Outpatient Prospective Payment System final rule includes new price transparency requirements with which hospitals must comply by specified dates. Here’s a checklist of what your hospital must accomplish and the related deadlines to avoid penalties. Because the final rule also strengthens the enforcement process for the price transparency rules—including more publicity of actions taken against individual hospitals—take action now to meet these requirements.
Compliance by January 1, 2024 – Improving Access to Hospital Machine-Readable Files (MRF)
- Make a good faith effort to ensure information encoded in the MRF is truly accurate and complete as of the date specified in the MRF.
- The final rule defines “encode” as converting hospital standard charge information into a machine-readable format that complies with 42 CFR § 180.50(c)(2).
- Ensure the public website selected to host the MRF establishes and maintains—in the form and manner specified by the Centers for Medicare & Medicaid Services (CMS)—a .txt file in the root folder that includes the hospital location name that corresponds to the MRF, the source page URL that hosts the MRF, a direct link to the MRF (the MRF URL), and hospital point of contact information. Read the .txt file technical specifications.
- Include a link in the footer on the hospital’s website (including but not limited to the homepage) that is labeled “Price Transparency” and links directly to a publicly available webpage that hosts the link to the MRF.
Compliance By July 1, 2024 – Format Standardization and New Data Elements
- Conform MRF to the CMS template layout, data specifications, and data dictionary (available at CMS’s Github repository). Required data elements include
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- MRF information (date, CMS template version, affirmation statement)
- Must encode “true” to the following statement: “The hospital, to the best of its knowledge and belief, has included all applicable standard charge information in accordance with the requirements of the regulation, and that the information displayed is true, accurate, and complete as of the date indicated in the MRF.” Encoding “false” will generate a deficiency.
- MRF information (date, CMS template version, affirmation statement)
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- Hospital information [name, location(s), address(es), licensure information].
- Standard charge information
- Gross charge
- Discounted cash price
- Payer and plan names
- Plans may be shown as categories (e.g., ‘‘all PPO plans’’) only if established payer-specific negotiated charges are applicable to each plan in the indicated category.
- Standard charge method
- Payer-specific negotiated charge
- Indicate whether the standard charge is a dollar amount or based on a percentage or algorithm (including a description of the percentage or algorithm that determines the dollar amount for the item or service)
- Additional notes
- De-identified maximum and minimum negotiated charges.
- Item and service information (general description, setting, inpatient/outpatient/both).
- Coding information (billing/accounting codes).
Note: it is strongly suggested that you use the CMS V2.0 Online Validator (https://cmsgov.github.io/hpt-tool/online-validator/) to review your uploaded MRF against the required CMS template layout and data specifications. If your MRF does not conform to the form and manner requirements, the Online Validator will generate an output consisting of “errors” and “warnings.”
Compliance By January 1, 2025 – Additional Required Data Elements
- Under standard charge information, report an “estimated allowed amount” when the payer-negotiated rate is based on an algorithm or percentage.
- “Estimated allowed amount” means the average reimbursement in dollars that has been received from the payer in the past for an item or service.
- Under item and service information, report drug unit and type of measurement.
- Under coding information, report modifiers impacting the “standard” charge, including a description of the modifier and how it would change the standard charge.
If you have specific questions regarding compliance with price transparency rules, our executives are happy to assist. Please contact them via email or at (800) 270-9629.
