How to Ensure Standardization of Files and Data for Consumer Access and Readability

Centers for Medicare & Medicaid Services (CMS) enforcement of new price transparency rules began in January, and ClaraPrice, which provides consulting services to hospital IT, revenue cycle, and compliance teams, is looking to help providers stay ahead of the curve on making the necessary adjustments.

Specifically, CMS is standardizing the machine-readable file (MRF). Hospitals must now display their standard charge information in a CMS template layout, following data specifications and a data dictionary.

Improved Accessibility for Oversight

Hospitals also must now place a “footer” at the bottom of their homepage. This footer must link to the webpage, which includes the MRF. It must include a .txt file with the following:

• Hospital location name, which corresponds to the machine-readable file;
• The source page URL that hosts the machine-readable file;
• A direct link to the machine-readable file in the URL; and
• Hospital point-of-contact information.

Affirmation Statement

Beginning July 1, 2024, each hospital must affirm that, to the best of its knowledge and belief, it has included all applicable standard charge information, and that the information encoded is true, accurate, and complete, as of the date specified.

Estimated Allowed Amount

A new data element, the estimated allowed amount, must be included in the MRF by Jan. 1, 2025. CMS also requires the listing of the historical allowed amount, an average reimbursement in dollars received from the payer in the past for an item or service. This data element will reflect the estimated dollar value when a standard charge is based on an algorithm or percentage. The estimated allowed amount supplements and does not replace the payer-specific negotiated charges for all items and services.

Enforcement Capabilities

In addition to the changes above, CMS has modified requirements to improve enforcement capabilities and increase transparency. Enforcement changes include the following:

• CMS will require the submission of certification by an authorized hospital official as to the accuracy and completeness of the data in the MRF and the submission of additional documentation to determine hospital compliance.
• CMS will also require hospitals to submit an acknowledgment of receipt of the warning notice in the form and manner specified in the notice of violation issued by CMS to the hospital by the deadline specified.
• CMS will publicize on the CMS website information related to a) CMS’s assessment of a hospital’s compliance, b) any compliance action taken against a hospital, and c) notifications sent to health system leadership.

Is your hospital compliant with the 2024 Price Transparency requirements? If you need help, please contact ClaraPrice for a free price transparency evaluation.

About the author:

Jory Hatton is the CEO of ClaraPrice, a healthcare IT corporation that specializes in the Medicare hospital price transparency rule and the No Surprises Act (NSA) compliance solutions. Jory has an academic background in computer science and enterprise software design, and a professional background in executive leadership ensuring client success and the innovative development of large-scale healthcare technology solutions.

Contact the author:

jory@claraprice.com