How Hospitals Can Avoid a Price Transparency Audit: Part III

EDITOR’S NOTE:
Jory Hatton, CEO for ClaraPrice, concludes his exclusive, three-part series for RACmonitor on the CMS Hospital Price Transparency rule.

Avoiding a CMS (Centers for Medicare & Medicaid Services) hospital price transparency audit involves ensuring compliance with CMS regulations regarding the federal transparency requirements. Here are some steps you can take to minimize the risk of being audited or penalized:

Understand the CMS Requirements

Familiarize yourself with the CMS requirements for hospital price transparency. These requirements, which have been expanded in 2024, include creating and posting a consumer-friendly list of shoppable services, preferably avoiding Excel or CSV, and publishing a comprehensive machine-readable file in a CMS-defined data template. Hospitals must use the CMS template in JSON or CSV format by July 1, 2024.

Implement Necessary Changes

Ensure that your hospital has implemented all necessary changes to comply with CMS regulations. This involves updating your website to include the cms-hpt.txt file required Jan. 1, 2024, placing links in the website header and footer, and updating all the necessary pricing information.

Regularly Review Compliance

Review your hospital’s price transparency compliance regularly. We suggest quarterly meetings to review all state and federal price transparency requirements to identify potential areas of non-compliance. This process may involve conducting internal audits or assessments to ensure that all required pricing information is provided accurately and routinely.

Document Compliance Efforts

Keep detailed records of your hospital’s price transparency compliance efforts, including any changes to your website or internal processes, to ensure compliance with the evolving regulations. If your hospital uses a vendor to manage your price transparency compliance, ensure that they do this for you. This documentation can be valuable in the event of an audit, demonstrating your hospital’s commitment to compliance. ClaraPrice, a team of hospital price transparency compliance experts, provides an administrative dashboard for hospital clients, allowing access to valuable analytics tools and a detailed data trail for historical purposes.

Stay Informed

Stay informed about any updates or changes to CMS regulations regarding price transparency. This may involve monitoring CMS price transparency guidance documents, participating in the Outpatient Prospective Payment System (OPPS) proposed rule comment period, and attending training sessions or webinars that CMS provides. Consider also creating a free GitHub account to monitor the technical implementation of new price transparency requirements, including the most recent version of the CMS machine-readable file. Users can follow the evolution of upcoming requirements, participate in group conversations, and contribute to improving the architecture of future data files and formats.

Address Issues Promptly

If your hospital is audited or identified as non-compliant with CMS regulations, promptly address any issues. This may involve researching the current requirements, updating your website, contacting outside experts, revising internal processes, or providing additional training to staff to ensure ongoing compliance. You will want to avoid CMS enforcement actions, which are routinely updated and revised, at all costs.

Seek Advice from a Compliance Expert

If you have concerns about your hospital’s compliance with CMS regulations or the potential for a price transparency audit, consider advice from a compliance expert. By taking these steps, you can help minimize the risk of such an audit and demonstrate your hospital’s commitment to compliance with regulatory requirements.