Price Transparency Updates Effective 1/1/24

New price transparency rules came into effect on January 1st. Has your team reviewed for compliance? Advis has prepared a summary of key provisions below. Should you have any questions regarding these CMS policies, please contact Advis at 708-478-7030 or via our website.

Standardization of Files and Data for Consumer Access and Readability

CMS is increasing the standardization of the machine-readable file (MRF) that processes hospital standard charge information. Hospitals must display their standard charge information by conforming to a CMS template layout, data specifications, and data dictionary. Previously, the use of CMS templates was voluntary. Now hospitals are required to conform to encode its standard charge information in the CMS templates and conform with other specified technical instructions that will be made available in a data dictionary.

Improved Accessibility for Oversight

CMS has finalized the requirement that hospitals place a ‘footer’ at the bottom of the hospital’s homepage that links to the webpage that includes the MRF and that hospitals ensure that the public website it selects to host its MRF establishes and maintains, in the form and manner specified by CMS, a .txt file in the root folder that includes the following:

  • The hospital location name that corresponds to the machine-readable file;
  • The source page URL that hosts the machine-readable file;
  • A direct link to the machine-readable file (the machine-readable file URL);
  • Hospital point of contact information.

Affirmation of Statement

Hospitals must make a good faith effort to ensure that the standard charge information encoded in the MRF is true, accurate, and complete as of the date indicated in the MRF. Note beginning July 1, 2024, the hospital must affirm in the MRF that, to the best of its knowledge and belief, the hospital has included all applicable standard charge information, and that the information encoded is true, accurate, and complete as of the date indicated.

Enforcement Capabilities

In addition to the changes explained above, CMS has also modified its enforcement provisions to improve enforcement capabilities and increase transparency. These modifications include the following:

  • CMS may require submission of certification by an authorized hospital official as to the accuracy and completeness of the data in the MRF and submission of additional documentation to determine hospital compliance.
  • Require hospitals to submit an acknowledgement of receipt of the warning notice in the form and manner and by the deadline specified in the notice of violation issued by CMS to the hospital.
  • If a hospital is part of a health system, CMS may notify health system leadership of the action and may work with health system leadership to address similar deficiencies for hospitals across the health system.
  • CMS may publicize on the CMS website information related to: 1) CMS’ assessment of a hospital’s compliance; 2) Any compliance action taken against a hospital; and (3) Notifications sent to health system leadership.

Published: January 5, 2024