The Centers for Medicare and Medicaid Services (CMS) requires all U.S. hospitals to “make public, via the internet, a list of the hospital’s standard charges for all items and services provided by the hospital.” This requirement was reinforced in the recently released Inpatient Prospective Payment System (IPPS) Fiscal Year 2019 Final Rule, which clarifies that the information must be provided in a “machine readable” format.
CMS also published frequently asked questions (here and here) and held a forum for hospital representatives to ask questions. Some key points of clarification include:
- Machine readable format is defined as a file that can be read by a computer system or analytical program. This includes a database file, such as XML, DBF, CSV and others.
- Only a “chargemaster” type file will satisfy this requirement.
- Charges for items and services do not include physician services charges.
Average charge per All Patient Refined Diagnostic Related Group (APRDRG) — searchable by hospital — is also published annually by the Maryland Health Care Commission, using information from the Health Services Cost Review Commission (HSCRC). MHA staff believe this publication satisfies the CMS requirement to establish and make public a list of their standard charges for each diagnosis related group.
To comply with the CMS rule, the Maryland Hospital Association, in coordination with hospitals members, recommends:
- Hospital charges should be posted on January 1 and July 1 annually to coincide with the effective dates of hospital rate orders.
- The machine-readable file should include the fields below. Hospitals suggest the information exclude Current Procedural Terminology (CPT) codes and other revenue codes because of copyright issues and differences among hospitals in the group of item charges, revenue codes, and rate centers.
- Hospitals include appropriate language explaining what information is posted, and any exclusions or limits on using this information. MHA staff drafted a sample, but each hospital should work with its compliance department and counsel to implement the rules.
- Hospitals include contact information to answer questions and respond to inquiries. If hospitals list a point of contact, that person should be familiar with billing issues and understand when to contact public relations, government affairs, or other staff to address inquiries from the media, consumer groups, health plans or elected officials.
Talking points are also available for MHA and hospital members to respond to the media, consumer advocates, or elected officials about this change.