Authors
Happy Monday and welcome to the final of three RFI’s in the RFI Comment Saga. Last but certainly not least is CMS’ Hospital Price Transparency Accuracy & Completeness RFI. This is a particularly interesting topic to us (and hopefully if you're reading this, you too) because it surfaces a nuanced yet critical question when it comes to assessing price transparency compliance: Is there merit in defining the “accuracy” and “completeness” of an MRF?
To that we say, sure is.
Read on for a snapshot of our responses or read the full thing here.
Our Responses Three Main Themes
Accuracy and completeness are essential for standardization across hospital and payer price transparency
CMS should specifically define this in terms of compliance and enforcement. Currently, accuracy is not explicitly defined, which results in numerous parties attempting to create their own definition. We strongly recommend consolidating around one standard definition of accuracy for hospital MRFs, one that can then be shared with payer MRFs.
Completeness is significantly easier to define and enforce. We recommend CMS create a simple definition of completeness that could look like the following: When assessing the completeness of a hospital MRF, CMS will study the total number of payers, payer plans, and individual billing codes associated with a hospital by cross-referencing the hospital MRF, any associated payer MRFs, and claims.
We must stop conflating accuracy with the perfect, patient legible MRF
In some cases, concerns about accuracy are really concerns about patient usage of this data. MRFs are not meant for patient usage as indicated by their machine-readable design. Through the lens of patient usage, concerns about accuracy are best showcased by the lack of accurate estimates. Questions of accuracy should thus be shifted to include Good Faith Estimate (GFE) and Advanced Explanation of Benefits (AEOB) from the No Surprises Act (NSA).
We support both efforts to drive more accurate pricing in hospital MRFs and efforts to bundle the data into service packages to achieve real usability beyond healthcare billing experts. The burden of creating a shoppable healthcare experience should not fall to patients, who cannot reasonably be expected to bundle rates on their own. That burden should be on health plans and hospitals within the already existing NSA framework, alongside the Patient Estimate Tool (PET) requirement in the hospital final rule.
Use this as an opportunity to improve support for hospitals
To improve compliance and enforcement processes, we recommend adding a column to the dataset specifically documenting the reason(s) for noncompliance, particularly where the “Action taken by CMS following a Hospital Price Transparency Compliance Review” indicates the hospital received a warning notice. The more visibility the public has into reasons for noncompliance, the more robust hospital price transparency resources will be in creating the most compliant files.
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