The Centers for Medicare & Medicaid Services (CMS) has introduced significant changes to the requirements for hospital price transparency. The aim is to enhance pricing transparency and ensure compliance with the rules. The changes are being implemented in phases from January 1, 2024, to January 1, 2025.
Easier Access to Hospital Machine-Readable Files (MRFs)
Effective January 1, 2024, hospitals are required to include a “Price Transparency” link in the footer of their website homepage. This link should guide users to a public webpage that hosts their MRF, a single digital file that contains standard hospital charge information.
In addition, a TXT (text) file should be located at the root of the public website that hosts the MRF. This file should contain the hospital location associated with the MRF, the URL of the source page hosting the MRF, a direct link to the MRF, and the contact information of the hospital. For information can be found by clicking here.
Standardizing Data Elements and Formats
CMS has introduced several updates to the MRF, effective from January 1, 2024. However, hospitals have been granted a grace period until July 1, 2024, to comply with these updates. Here are some key changes:
A More Detailed Format
From July 1, hospitals will need to adhere to stricter technical standards, including the use of a new MRF template. This template, available in CSV format or JSON schema, will standardize the layout and data specifications. The MRF will include data elements such as the hospital’s name, license number, and location details. If applicable, it will also list the locations and addresses of all associated inpatient facilities and standalone emergency departments. The file format (CSV or JSON) and the date of the last update will also be documented.
Expanded Charge Detail
Starting July 1, hospitals will need to certify in their MRF that all standard-charge data is accurately and completely encoded to the best of their knowledge. This certification aims to reduce confusion when fields are left blank because they’re not applicable, rather than due to oversight or rule evasion.
The categories of standard charges, including payer-specific negotiated charges, will remain the same. However, by July 1, the payer and the specific health plan must be identified as separate data elements for each charge. Plans can be grouped (for example, “all PPO plans”) when the charge applies to all such plans.
MRFs will also need to include the contracting method used to determine each negotiated charge and whether the charge should be interpreted as a dollar amount, a percentage, or an algorithm. If it’s a percentage or an algorithm, the MRF must clarify how the dollar amount is calculated. Hospitals will also need to update their MRFs to convert the percentage or algorithm into an estimated allowed amount in dollars. This requirement will not be implemented until January 1, 2025.
Expanded Item and Service Information
Starting in July, each charge’s associated item or service will need to include a general description and a note specifying whether it’s provided during an inpatient admission or an outpatient encounter. For 2025, pharmaceuticals will need to specify the drug unit and measurement type.
Additionally, hospitals will need to provide billing and coding information (such as CPT and HCPCS codes, DRGs, National Drug Codes, and Revenue Center Codes) for the item or service associated with the standard charge starting in July. Relevant modifiers will need to be included beginning January 1, 2025.
New Enforcement Actions
CMS may start requiring hospitals to certify the accuracy and completeness of their standard-charge information in the MRF. Compliance checks could extend beyond simple website audits to more comprehensive reviews of a hospital’s standard-charge information.
Enforcement actions will become more publicly accessible. While currently only noncompliant hospitals that have received penalties are listed on a public webpage, soon all hospitals will be included. Each hospital’s compliance status will be shown, and for those not in compliance, the status of enforcement actions, including warnings, will be detailed.
Online Tools
CMS released an updated Online Validator tool on March 28, 2024. The Online Validator reviews an uploaded MRF against the required CMS template layout and data specifications. If the MRF does not conform to the requirements, the Online Validator will generate an output consisting of ‘errors’ and ‘warnings’. ‘Errors’ represent requirements that are enforced beginning July 1, 2024, while ‘warnings’ represent requirements that are enforced beginning January 1, 2025. This tool, along with others such as the text file generator, can be found by clicking here.
Blue Can Help
Our team of experienced consultants is here to assist your hospital with the 2024 and 2025 posting requirements. Since the implementation of Price Transparency, we have helped many hospitals develop and maintain their machine-readable files. Please reach out to a member of our revenue cycle team below or your local Blue & Co. advisor today.
