11月1日, 2023, CMS发布了2024年门诊预期支付系统的最终规则, 其中包含了对医院新的价格透明度要求. With these new rules CMS is signaling that it is serious about price transparency by increasing disclosure requirements, 标准化数据格式，方便第三方进行聚合, 加强监管和执法力度. While the industry had been slow to embrace the pricing transparency requirements since they went into effect in 2021, 现在很清楚的是，回避策略不会长期有效.
Background
The requirement for hospital pricing transparency originated with an executive order signed by then-President Donald Trump in June 2019 and citing the Affordable Care Act as the source of its legislative authority. The first set of proposed rules from CMS was published in November of that year, 最终规定将于明年1月1日生效, 2021. These rules called for hospitals to make available on their websites two sets of pricing data. The first set was for 300 “shoppable services” designed to allow consumers to directly compare hospitals’ costs of services against one another. The second set pertained to machine-readable files (MRFs) containing comprehensive prices for all items and services provided by a hospital. These files are intended to facilitate downloading, aggregation, and dissemination by third parties.
整个行业在接受新要求方面进展缓慢, 由于各种原因，许多公司在2020年采取了很少或没有采取措施来遵守规定:
- 医院对公开协商后的价格持严重保留态度.
- 许多人认为这一要求的合法性值得怀疑, and the American Hospital Association led an unsuccessful lawsuit to have it repealed.
- The COVID pandemic became the overwhelming priority for the industry throughout almost all of 2020.
- There was considerable uncertainty regarding who would be elected president in 2020 and whether Joe Biden, 他会赢吗?, 是否会优先考虑价格透明度.
- The penalties for noncompliance were relatively light at $300 per day ($109,500 per year).
尽管业界犹豫不决, the Biden administration has demonstrated its resolve in ensuring that price transparency becomes a reality, first by significantly stepping up the penalties for noncompliance in 2022 and now by adding new requirements for the comprehensive files that appear to be designed to facilitate the aggregation and dissemination of this data.
新规则摘要
2024年CY规则包含了不少新的报告要求, 其中几项将于1月1日生效.
- The first is that hospitals must make a good faith effort to meet CMS’s reporting requirements. 目前还不清楚这能达到什么效果, 因为实际遵守, 而且不仅仅是善意的努力, 这是监管机构通常寻找的东西吗.
- CMS is also requiring hospitals to post certain information on their websites that will help users navigate to the pricing transparency information and provide the hospital’s point of contact information.
The more substantive requirements go into effect on July 1, 2024, and address the comprehensive MRF. 它们包括以下内容:
其他医院信息
核磁共振成像必须包括所报告的医院信息, 例如它的名称和许可证号码. At first this requirement may seem unnecessary because the user would presumably already know this information, 在医院的网站上找到的. 然而, including this information in the file itself will assist with data aggregation across large numbers of hospitals, 你的意图是什么.
有关付款方法的资料
直到现在, CMS只要求医院报告他们的协商价格, 以美元表示, for items and services; CMS was not concerned with the methodology for determining those amounts. 七月开始, hospitals will need to express this information as a percentage of charges or other algorithm as applicable, 以及为这些bet8娱乐支付的历史金额. In effect, this allows third parties to reconstruct a payer’s payment methodology.
认证
除了价格相关的信息, a hospital’s designated representative will need to provide an attestation that all the information contained in the MRF is complete and accurate to the best of their knowledge. CMS believes this will better enable it to enforce accountability and resolve any outstanding questions regarding the data being submitted.
增加执行
从2024年开始, CMS will reserve the right to conduct comprehensive compliance review of a hospital’s standard charge information and to publish the results of that review, along with any compliance actions taken against the hospital and any notifications sent to health system leadership. 这是对CMS当前执行的审计的补充, which have increased significantly in number since the program was first implemented.
交叉参照保险价格透明度数据
最后, 虽然不是新规则本身的一部分, it is worth noting that the insurance transparency data provides CMS with an additional data source against which to validate the data published by the hospital. CMS could use this data to validate that a hospital’s data includes all plans for which it has negotiated rates, 包括所有的项目和bet8娱乐, 报告的比率是准确的.
对医院的影响
The most pressing and glaring implication for hospitals is that this requirement will involve a sizable effort to comply with—and noncompliance is no longer an option. CMS不仅加大了识别违规者的力度, 这增加了被发现的风险, 其中包括公开披露责任人. Clearly, this is not the way that most healthcare executives want to make the news.
第二个暗示是医院公布的比率, 再加上健康计划现在必须提供的价格信息, will have a major impact on the way providers negotiate their contracts with payers. 整体, this is likely to produce further downward pressure on rates as consumers exercise their ability to identify and select lower-cost providers. 类似的, 购买者将有更大的能力看到他们的竞争对手在支付什么, and those who pay relatively high rates will push hard to reduce their rates to those of their competitors.
为了控制这些影响, providers will need to become much more sophisticated and strategic about how they price their services. It may no longer make sense to seek across-the-board rate increases; instead, hospitals will need to determine which services are commodities to be priced competitively and which ones are differentiated, 这样医院就能得到高价. 对于后一类, hospitals will need to be prepared to substantiate their position with hard data regarding quality and safety, 结果, 病人的体验.
心电图专家可以帮助您的组织满足这些要求.
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