CMS to Audit and Monitor Hospital Price Transparency

By: Kristen Andrews Wilson, Aleah M. Schutze

Published: January 6, 2021

On January 1, 2021, hospitals and health systems will be required to comply with Hospital Price Transparency requirements or face possible penalties from the Centers of Medicare and Medicaid Services (CMS). This rule requires hospitals and health systems to disclose a comprehensive list of standard charges for all items and services and a consumer-friendly list of prices associated with a narrower “shoppable” set of services. The standard charges include: (1) gross charge; (2) discounted cash price; (3) payer-specific negotiated charge; (4) de-identified minimum negotiated charge; and (5) de-identified maximum negotiated charge. The list is to be provided in a comprehensive machine-readable file with all items and services.

CMS has stated that it plans to audit a sample of hospitals in January 2021 for compliance with this rule, in addition to investigating complaints. For hospitals that are not in compliance, CMS may issue a warning, request a Corrective Action Plan or impose a Civil Monetary Penalty not in excess of $300 per day and publicize the penalty on CMS’ website.

For questions on compliance with the Hospital Price Transparency requirements, please contact one of the authors of this alert.

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