CDM Transparency – 1Q19 update


The CMS “Pricing Transparency” regulatory requirements kept hospitals and their trusted consulting partners busy over the past few months.

This article shares information on the current state of the industry, hospital needs, best practices, benefits of chargemaster software, and expectations for the future.


Where we are Today

In December, chargemaster publication was on everyone’s minds. CMS’ guidance left unanswered questions and led to increased speculation on technical details of the mandate. All this created a flurry of hospital meetings as well as vendor and consulting involvement. The industry received some clarity through multiple CMS Q&A documents (see exhibits 1 and 2), but specific instructions came late in the year, causing numerous hospitals to miss the January 1st deadline.

We’re now months into the mandate, and much has unfolded. Hospitals have taken dramatically different approaches to chargemaster access. The display format of chargemaster data is widely-varied, and the content of the public view price list is diverse. It’s been no surprise that some hospitals have posted well-maintained charge data while others are displaying information that would confuse the savviest shopper.

Pricing display applications were rolled out by several vendors (including our company as noted in this press release-Holliday and Associates Offers US Healthcare Systems Access to Public Portal. Based on our preliminary surveys, we see variation in website locations, charge master displays, disclaimer texts, and guidance on how the shopper can receive an estimate of out of pocket costs.

The Holliday & Associates team and our consulting peers continue to be concerned with last year’s lack of clear and timely CMS guidance on the price transparency regulation. We heard about many hospitals trying to “read between the lines” of the limited language. Many hospitals spent significant time discussing the mandate and deliberating the intricacies of their internal action plan.

Stories of incorrect regulatory interpretations, inaccurate consulting/vendor guidance, and even marketing scare tactics have surfaced now that we are several months into this regulation. With the transparency mandate, we are now seeing hospital chargemaster files that have been poorly maintained, yet are in full view for the scrutiny of the press, peers, and the public.

The last 60 days of hospital price transparency have taught us that the chargemaster and underlying pricing strategies are under the spotlight, and will continue to be scrutinized in the current marketplace.

Hospital Commitments

Often serving as community leaders, hospital executives and their communications staff are in a position to educate the public on hospital pricing. Strategic hospitals have begun to embrace price transparency’s public relations aspects and address challenges professionally.

Our proactive customers strive to go beyond the Medicare requirements with these actions:

  • Ensuring a compliant ‘public view’ price list
  • Curating a positive public image with user-friendly functions such as:
      • Simple access from the hospital landing page
      • Search functionality for finding charges (such as the ChargeAssist® CDM Public Portal)
      • Insurance-specific out of pocket cost estimations
      • Explanations of charge data or charge practices
      • Easily understood (or easily-researched) verbiage for line item charges
      • A trained and knowledgeable hospital contact for price/chargemaster questions
  • Maintaining chargemaster data that has consistently:
        • Accurate Content
        • Clear Descriptions
        • Defensible prices

Focus on Best Practices

Every local hospital is under the microscope as the public peruses their pricing files. Here at Holliday & Associates, we think the best approach for transparency is assuring accurate and supportable charge data and pricing.

In short, hospitals can no longer tolerate erroneous charge data or poorly-defended charge practices.

Here are some areas hospitals have been addressing during the first part of 2019 to ensure a positive image:

    • Assessing and refining the public view chargemaster file (focusing on creating a consumer-friendly impression while upholding strategic, compliance, and payment system mandates)
    • Evaluating Charge Master software or considering changes in software vendors (for internal charge data maintenance, management and monitoring)
    • Conducting Charge Management educational programs (to train individuals or teams to ensure coordinated and proactive approaches to charge data)
    • Engaging Charge Master Review consulting projects (to ensure accurate data, better ownership, and more effective processes)
    • Performing Pricing Studies (to analyze hospital charge amounts and evaluate how price changes should be staged)

Are CDM Tools Needed for Transparency?

In short, no. There is no mandate requiring purchase of data, consulting or software. However, the benefits of Charge Master software are profound and often overlooked as a long term solution to assured data integrity and effective work flow processes.

  • Organizations now understand the benefits of CDM tools
  • Hospitals are now looking for alternative, quality vendors as their current vendor agreements are expiring
  • Investment in charge management solutions has become more selective, and hospitals are focused on long term internalized improvements
  • Duplicated or unnecessary expenditures in coding, reimbursement and regulatory resources are being scrutinized
  • Collaborative department engagement is finally being embraced for charge management
  • Next generation Charge Master software technology is being adopted that guides users through more sophisticated use of reference, auditing, and process management functions
  • Resource needs (staffing, consulting, service providers, education, information systems, memberships, data, documentation, etc.) are now evaluated in a house-wide cost/benefit manner

Planning Ahead for 2020

Hospitals should use 2019 as a time to ensure chargemaster accuracy and proactive file management.

Some may need to make or change software investments. Others may seek consulting assistance. And some hospitals have already proven that their established processes and support resources are sound.

Like the June 24th Executive Order, there will be more information in the future. More details from CMS will be announced in future rulemaking. We expect additional and possibly expanded regulatory guidance in the 2020 IPPS Proposed Rule. CMS will most likely develop mechanisms to monitor the industry for compliance. They will possibly publicize or penalize those who have not yet published their data. We may also see more specific or expanded data publication specifications as well.

If your hospital doesn’t have a robust charge management program, perhaps it’s time to explore your options. Call us if your team needs help developing a charge data improvement plan.

Holliday & Associates offers the ChargeAssist® CDM Public Portal to new customers as well as within our ChargeAssist® software product- an HFMA Peer Reviewed™ Charge Master auditing and resource tool for easily auditing, collaborating, and maintaining Charge Master files. We also provide Charge Management CDM Coordinator Education and CDM Reviews by a team of credentialed clinical, coding and technical auditors.

Contact information: (800) 831-3323 | Web Site: |

To read more about Hospital Price Transparency, read through our other articles:
Price Transparency “Round 2”– CMS Seeks Input
The Chargemaster: What your Shopping Public Needs to Know
CDM Transparency – More speculation & More confusion
Frequently Asked Questions Regarding Requirements for Hospitals To Make Public a List of Their Standard Charges via the Internet
Q&A from CMS Leaves Hospital Questions Unanswered
IPPS CDM Public Access Announcement Causing Confusion & Concerns: Tips for Hospital Action Plans