Effective January 1, 2021, hospitals are required to post standard charges in a machine-readable file and post their negotiated rates online for 300 "shoppable" services, 70 of which are pre-selected by the Centers for Medicare and Medicaid Services (CMS).
“Standard charges” include the gross charges, payer-specific negotiated charges, the amount the hospital is willing to accept in cash from a patient, and the minimum and maximum negotiated charges.
Compliance vs. Penalty
A decision is pending on an appeal fighting the law but a ruling before the January 1 start date, only days away, is unlikely. Hospitals are preparing for implementation. Those that were considering absorbing the $300 a day penalty are reconsidering given the CMS' Inpatient Prospective Payment System final rule for 2021. It proposed denial of Medicare payments as a penalty. That is much more than most hospitals are willing and able to absorb.
Price Estimator Tool
One way hospitals can meet the requirements for Making Public Standard Charges for Shoppable Services is by maintaining an internet-based price estimator tool. According to the Code of Federal Regulations at 45 CFR §180.60(a)(2):
A hospital is deemed by CMS to meet the requirements of this section if the hospital maintains an internet-based price estimator tool which meets the following requirements.
(i) Provides estimates for as many of the 70 CMS-specified shoppable services that are provided by the hospital, and as many additional hospital-selected shoppable services as is necessary for a combined total of at least 300 shoppable services.
(ii) Allows healthcare consumers to, at the time they use the tool, obtain an estimate of the amount they will be obligated to pay the hospital for the shoppable service.
(iii) Is prominently displayed on the hospital's website and accessible to the public without charge and without having to register or establish a user account or password.
Centauri can create a user interface that generates a web view based on the provider’s specific requirements and has a machine-readable file for CDM items and their rates. We can also create a user tool to select any of the 300 shoppable services in a consumer- friendly format. User views can be customized to each facility’s unique strategy in releasing this information. There is no software to install, allowing for quick implementation.
Estimates in Scheduling Workflow
The mandate does not encompass or resolve all of the issues around price transparency. Including out-of-pocket estimates into a scheduling workflow is key to prepare patients deductibles and co-insurance in advance of a visit or service. Surprise costs at the point of service can lead to bad customer service experiencing or patients turning away from a scheduled service creating missed revenue opportunities and under-utilized schedules.
Shanna Hanson, FHFMA, ACB
Manager, Business Knowledge
Centauri Health Solutions, Inc.