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Price Transparency Executive Order Playbook

Feel free to browse through these resources for the latest updates and requirements to meet the price transparency Executive Order.

Requirements for the January 1, 2021 Mandate:

Beginning January 1, 2021, healthcare providers will be required to publish payer-specific negotiated rates and a list of 300 shoppable services. Specific requirements include:

  • CDM File with Gross and Negotiated Charge
  • Minimum of 300 Shoppable items with 70 CMS defined and 230-plus defined by hospital
  • Published in an easy to understand, consumer friendly and machine readable format
  • Updated quarterly

See a sample webpage with negotiated charges and shoppable services

Additional Resources:

List of CMS 70 Shoppable Services

Final Rule: 2020 Medicare Hospital OPPS and ASC Payment System Hospital Price Transparency Requirements (CMS-1717-F2)

Fact Sheet: 2020 Medicare Hospital OPPS and ASC Payment System Final Rule Hospital Price Transparency Requirements (CMS-1717-F2)

Remarks by CMS Administrator Seema Verma at AHA Policy Board Meeting 

Webinar Series:

Price Transparency Final Rule: How to Prepare in 2020

December 5, 2019 | 30 Minute Video

Watch the Webinar Recording

After reviewing public comments, the price transparency final rule has been released and is effective Jan 1, 2021. 2020 is now a critical year for hospitals and health systems to prepare to publish pricing for items and services – and to understand how this will impact your organization going forward.
This webinar will cover the following:
  • The details of the hospital price transparency final rule and updates since the proposed rule
  • The options for meeting the mandate, including how to publish shoppable services
  • Your readiness checklist and the key roles that need to be involved
  • Why pricing transparency needs to be a strategic initiative for your hospital in 2020

Executive Order Update: The Delay and How to Respond

November 7, 2019 | 30 Minute Video

Watch the Webinar Recording

The price transparency mandate was not included as part of the Outpatient Prospective Payment System (OPPS) final rule. However, this does not mean that it will not happen. So how do you prepare now?

The 30 minute session will focus on:

  • The latest update on the final rule
  • Internal leadership team – who should be involved from your organization to successfully meet the mandate
  • Technology checklist – the technology you should have in place to prepare 
  • Communication and education – how to present and communicate newly required pricing information to patients

*Check back or follow us on LinkedIn for more upcoming webinars on how to prepare for the Executive Order

Frequently Asked Questions (FAQs):

Q: Do you know if these requirements apply to hospital inpatient and hospital outpatient services only?

A: Our interpretation is the new requirement should be consistent with the 1/1/2019 mandate which called for all items and services listed in the hospital CDM (i.e. standard price list) should be included.  This would cover inpatient, outpatient and other services that your organization may bill for.

Q: Are ASCs required to report this information? 

A: Currently, free-standing ASC are not required to post this information but the free-standing ASC industry is preparing / planning for this requirement in the near future.   Hospital-based ASC’s will be required to post this information as a part of the hospital’s CDM. 

Q: Are professional services provided in the hospital also required to be priced? 

A: If the hospital has hospital-based clinics and bills for professional services, then yes.  In the list of CMS-provided (70) shoppable items, E&M services are listed. 

Q: Are professional services in a clinic owned by a hospital system required to be priced?

A: Yes. 

Q: Is the proposed requirement to publish CPT and revenue code also on hold for now?

A: Yes, that’s correct. The entire set of price transparency rules were put on hold for now. If you review the comments that were listed, there were a few comments related to CPT codes but there were very few comments related to that being a large industry concern. We don’t see that as being a controversial issue and is likely something that CMS will be moving forward with in the final rule. 

Q: So when do we think the rule will be released?

A: That’s really the big unknown question right now. CMS has not put out anything definitive in terms of a time frame. Obviously there are some people that would project it out to be as early as the next few weeks. There was an article in Modern Healthcare yesterday that indicated it would be after the first of the year. I think most individuals don’t anticipate this going further than Q1. So sometime over the next 1 week to 3 months would probably be a reasonable time frame.

Q: Do you feel that the deadline will still be January 1st even with the delay of the finalized rule?

A: CMS indicated that the rules from the comment period should be considered final (unless CMS posts something to the contrary). I think there is a hope that because they released the other OPPS rules without speaking to pricing transparency, that it has been delayed. That is probably more of a hope than something specific. They have not indicated a wavering from the Jan 1 date; they’ve only elected to move the other things forward without specifically addressing it.

Q: While this new rule is on delay are we still held to prior years’ regulations?

A: Yes. The one that went into effect Jan 1 2019 was completely separate so it still stands.

Need Help with a Strategy?

PMMC is helping healthcare providers both meet the mandate and put a real price transparency strategy in place going forward. Contact us today to get started.

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