The Centers for Medicare & Medicaid Services’ have issued a proposal to update their Price Transparency Rules, which if approved would make all pricing data more accessible to consumers through new billing templates, requirements, and compliance rules. The Rule, which would take effect January 1, 2024, would require all hospitals to follow a specific billing template so that CMS can seamlessly comb through data to ensure compliance. The template would call for more clarity from hospitals on all contributing factors that go into a service, vs a standard bucketed rate. To ensure hospitals are compliant, CMS would publish a public list of the hospitals that are compliant and those that are not to increase pressure on delinquent hospitals. Previously CMS would send a letter to the general system to alert them of compliance matters and fines, but this proposed Rule would give CMS the ability to send letters directly to Hospital leadership so that there is a paper trail and receipt to track all executives that have been notified that their hospital is not compliant.
Lastly, the proposed Rule would give consumers a choice when shopping for services. They can either see the total cost of a service upfront in a fixed fee dollar amount, so they know the expected price, or they may use the CMS algorithm, which offers a range of how much the service might cost. These libraries of shoppable services would be more readily available and more user friendly, so patients can better understand all of the details and price points that go into care and treatment.
AHA has already pushed back publicly on the proposed bill, noting that requiring hospitals with price estimator tools to invest time and resources in creating a shoppable service list, in addition to complying with the Advanced Explanation of Benefits, is a move in the wrong direction and will cause additional burden on already stretched health system teams.
While CMS seeks final approval of these Rules this fall, hospitals should be considering these key steps for preparing to address the proposed CMS Price Transparency rules with external stakeholders, including consumers and media.
Know the media landscape and the potential stories that may pop.
As we have seen over the past few years, hospitals and health systems are facing increased scrutiny for their role in the cost of healthcare in the U.S. Locally, we have seen reporters dig into the data to compare systems in their community. Look back to the stories in your market over the past few years since the launch of Price Transparency rules in 2021 to better understand how to combat the news cycle this time around. Given the likely uptick in reporting, systems should be prepared to handle questions from media around their planned level of compliance.
Use this time to develop and unleash your value narrative across the local community.
Given the changes and availability of pricing information through new rules that CMS is proposing, coupled with the already ongoing assault of hospital pricing, patient and consumer trust in healthcare providers is declining. Right now, hospitals need to focus communications on the value they provide local communities to remind key audiences of the impact they make both inside and outside of the hospital. Doing this now would build up goodwill and help to counter negativity that the CMS changes may bring in media headlines and community conversations.
Consider the additional burden this would put on administrative teams and the impact to patient care.
Prepare messaging that highlights how these proposed rules would lead to additional burden on already stretched administrative teams and may create confusion for both the providers and patients when determining the right treatment plans. Preparing this information now will allow you to disseminate it quickly and efficiently if the Rule is approved and media or community requests come your way.
If you would like to discuss these rules with our team of experts, please reach out to mpetrone@reviveagency.com to set up a time.
