What you should know

  1. The Center for Medicare and Medicaid Services’ (CMS) final “OPPS” rule standardizes hospital MRF formatting, expands hospital MRF data elements, and enhances enforcement mechanisms around hospital MRF compliance.
  2. Rule provisions have varying compliance dates, ranging from 1/1/24 to 7/1/24 to 1/1/25.
  3. In addition to these requirements, last week CMS released several similar finalized payment rules, including those for hospital/ASC reimbursements, clinician reimbursements, and the 340B drug discount program. None of those other rules contain transparency provisions.
  4. CMS also published its Hospital Price Transparency GitHub repository, which includes technical specifications and an implementation timeline for the new requirements.

What this could mean for you

  1. Hospitals will be required to affirm the accuracy and completeness of their standard charge information displayed in their MRFs.
  2. Data elements (including coding info) must be included in the standard charge list to improve standardization of hospital MRF formats.
  3. Hospitals must meet specific formatting requirements for display of standard charge information using a CMS template.
  4. Specific monitoring/enforcement mechanisms related to these requirements, including actions CMS may take to address noncompliance of hospitals in health systems and publicizing assessments, compliance actions, and outcomes on the CMS website.
  5. While the rule’s requirements apply only to hospital MRFs, the rule could be a harbinger of more standardized formats and expanded or restricted data elements for health plan MRFs.

The full final rule can be viewed here, and a CMS fact sheet can be found here.