CMS released the 2020 OPPS proposed rule on 8/9/2019. Although it is for PPS hospitals this year CAHs are affected as well. The proposed requirements for Price Transparency effective 1/1/2020 as written will be a tremendous burden on rural and critical access hospitals. Comments on the proposed rule will only be open until 09/27/2019.
It is vital that you submit comments to CMS at this link prior to that date!
Key proposed requirements include:
- Publishing in machine readable format your chargemaster. This year with the following data points required:
o Description
o CPT/HCPCS code
o Revenue Code
o Charge amount
New for 2020:
- Publishing in a patient friendly format
o 300 “shoppable” services (70 required from a CMS specific list)
o Hospital pricing for each service
o ALL Negotiated rates for those services (All contracted pricing must be included not matter how many contracts with insurers you have. Exception is governmental payers)
o A way to compare these prices
Bundled services will have to be broken down into components and supplies.
New for 2020 are penalties for non-compliance. Penalties will include:
- Notice of non-compliance
- Action plan required
- Fines of $300/day until compliance is achieved.
- CMS will use these methods for determining compliance
o Website audits and reviews
o Complaint follow up from the communities
CMS has estimated the cost to hospitals to implement will be $1017.24. They are estimating using the opinion that all hospitals have their contracted prices loaded into their electronic systems and the rates should be easy to pull out of said systems. If this is not true for your hospital please let CMS know!
The patient friendly portion may also be an additional cost. Hometown Health is vetting several vendors to assist. The minimum cost so far is an annual fee of $5000. If you are a CAH this money will actually be a cost to the Medicare program when all costs are reported at the end of the year.Please tell CMS this defeats the purpose of lowering the cost of healthcare.
Another note to include in your comments to CMS would be that due to the lack of resources in rural hospitals, expecting this to be accomplished by 1/1/2020 is unreasonable and should be postponed.
If CMS does not receive comments, your hospital will be affected! Submit your comments now!