The Affordable Care Act (ACA) and subsequent guidance from the Centers for Medicare & Medicaid Services (CMS) in fiscal years 2015 and 2019 IPPS rules require every hospital, beginning Jan. 1, 2019, to publish a list of standard charges for all items and services provided by the hospital on an annual basis. The hospital must make the list available on a public-facing website in a machine-readable format.
CMS, in response to questions from the American Hospital Association (AHA), has clarified to AHA that grouping charges would not satisfy the requirement. It is widely recognized, including by CMS, that hospital chargemaster information is not helpful for consumers.
During a CMS Open Door Forum on Nov. 13, CMS stated publicly to post “all items and services” according to the chargemaster. If the items and services are being completed at the facility at a zero sum charge, these items and services need to be posted as well. CMS also mentioned that they do not know of an alternate means outside of the chargemaster. The structure and design of the machine readable file has been left up to the hospital but CMS reiterated the format must contain all items and services for both inpatient and outpatient charges.
CMS has not said how it will enforce the transparency requirement but indicated that they are considering making information regarding noncompliance public. CMS is seeking comments on the most appropriate mechanism for enforcing the requirement, among other issues.
The South Dakota Association of Healthcare Organizations (SDAHO) has prepared a brief for SDAHO members to help explain the rule’s requirements and how to communicate with patients and media about the chargemaster and related price transparency issues. SDAHO will alert members when additional information becomes available.