CDM Transparency – More speculation & More confusion

(Another blog in the H&A “CDM Transparency” Series)

Late in the year, we find ourselves working with limited details and much industry concern about the CMS’ Charge Master publication requirements. Here at H&A, we’ve been collaborating with colleagues and clients alike to hear what hospitals are planning. At this point, most hospitals have decided to move forward despite a lack of specificity on the January 1st mandate.


Where we are today

Chargemaster Publication is on everyone’s minds. CMS’ FAQ and Final Rule guidance, as we have noted before, have left unanswered questions and led to increased speculation. We had hoped for more clarity and official direction. As of late-December 2018, we wanted to catch readers up on additional details on the Chargemaster Transparency topic.

This post summarizes what we think are the four basic steps your team needs to take to comply. We’ve also included input on industry misinformation that has caused confusion.

The Holliday & Associates team as well as our consulting peers have been long-concerned about the lack of clear and timely CMS guidance on the price transparency /Charge Master Publication regulation, and are noting widespread industry concern. We’ve observed many hospitals trying to “read between the lines” of the limited language, and many have spent significant time discussing the mandate. Unfortunately, we have also noticed some companies ‘over-interpreting’ the language from CMS with guidance based on opinion rather than fact.

Here at H&A, we think the best approach is having the following four items ready & available by January 1st:

  • First, a charge item look up or export file (such as the ChargeAssist® CDM Public Portal or an appropriately-formatted file meeting CMS “machine-readable” definition)
  • Second, DRG-specific average charges listing (available in the ChargeAssist® pricing module) referencing Medicare standard analytical file (claims) data
  • Third, patient educational information about charges (see our next article for example language), and
  • Fourth, details of how patients can obtain an estimate of their out of pocket costs (through a call to your hospital, an estimator software tool, etc.)

Then, be ready to refine your approach if CMS provides greater clarity or additional mandates.

Rumors & Misinformation

We also wanted to dispel some rumored requirements that seem to have cropped up in the last few weeks:

  • CMS has not asked hospitals to display competitive market information. There are many considerations when providing market data. Publishing comparative rates can lead to patient confusion or future challenges if not calculated and portrayed appropriately.
  • CMS has not asked hospitals to display AWP information. Although they did state that pharmacy or other charges coming from alternative applications must be included in the data posted, they are not asking for cost or pricing mark-up formulas.
  • The ACA requirements for IPPS hospitals to make available their DRG average charge information does not state that hospitals must aggregate current prices against DRGs. Most now believe the use of claims-based Medicare average charges for this information meets the requirement.
  • Neither Strategic Pricing Studies, nor Patient Price estimators, Comparative Pricing Websites, Charge Master Reviews, or special software are mandated or required to comply with the CMS rules. While various consulting and software functions will improve your organization’s reputation as your data is scrutinized, CMS is not requiring any special investments beyond making data publicly available.
  • Display of every data element in your CDM, EAP, or other charge files has not been stipulated by CMS. We (and many others) feel that only charge item identifier (number, description, etc.) price, and possibly other helpful fields like department/cost center/billing category/charge type are the fields that represent hospital charges, and most useful for the shopping public  to see your charge item pricing. (Despite announcements of data that can/can’t be published and required copyright notices, we only suggest limited fields in your public view file.)
  • Beyond the aforementioned DRG information, aggregated procedure-based charges, average prices for specific codes, and ranges of certain charge items are not currently required by CMS in the Medicare mandate.
  • Pricing updates and CDM revisions are not restricted under the CMS publication guidance. CMS merely states that the file is displayed annually or “more often as appropriate”.

It’s likely that more details from CMS may be announced in future communications. At this point, however, hospitals should move forward with their best efforts to develop a public display file export along with ways to educate your patients and inform them of estimated out of pocket costs. You’ve hopefully cleaned up your public view CDM to remove non-charged items and included a snapshot of prices for any price override items that may be coming from other ancillary applications or files. If a ChargeAssist user, you also have most likely looked at the CDM Public Portal to see if you’d like to roll it out.

If you are confused about what you’re hearing about the CMS requirements, we are happy to discuss what we know as well as what we don’t know.

Please refer to past posts that include the two FAQs from CMS, IPPS Final Rule language, early ACA language, and suggestions for preparing for publication. Also watch for our upcoming The Chargemaster: What Your Shopping Public Needs to Know available soon.

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.

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