This post section includes Medicare’s original FAQ document on Price Transparency. (Further CMS FAQs are in the section that follows.)

Frequently Asked Questions Regarding Requirements for Hospitals To Make Public a List of Their Standard Charges via the Internet

Q. What format is a hospital required to use to make public a list of their standard charges via the Internet?
A. The format is the hospital’s choice as long as the information represents the hospital’s current standard charges as reflected in its chargemaster.

Q. Do the requirements apply to all items and services provided by the hospital?
A. The current requirements apply to all items and services provided by the hospital.

Q. Do the requirements restrict a hospital from posting quality information or additional price transparency information?
A. CMS encourages hospitals to undertake efforts to engage in consumer friendly communication of their charges to help patients understand what their potential financial liability might be for services they obtain at the hospital, and to enable patients to compare charges for similar services across hospitals. A hospital is not precluded from posting quality information or price transparency information in addition to its current standard charges in its chargemaster.

Q. What is the definition of “machine-readable” for purposes of the requirements?
A. By definition, machine readable format is a digitally accessible document but more narrowly defined to include only formats that can be easily imported/read into a computer system (e.g., XML, CSV). A PDF, on the other hand, can be a digitally accessible document but cannot be easily imported/read into a computer system.

Q. What hospitals are required to make public a list of their standard charges via the Internet?
A. In the FY 2015 IPPS/LTCH proposed rule and final rule (79 FR 28169 and 79 FR 50146, respectively), CMS noted that section 2718(e) of the Public Health Service Act, which was enacted as part of the Affordable Care Act, requires that each hospital operating within the United States, for each year, establish (and update) and make public (in accordance with guidelines developed by the Secretary) a list of the hospital’s standard charges for items and services provided by the hospital. There are no hospitals operating within the United States with exemptions from this requirement under the current policy.

Q. Does participation in a state online price transparency initiative satisfy the federal requirements?
A. CMS is fully supportive of and encourages state price transparency initiatives. However, under the current guidelines, participation in an online state price transparency initiative does not exempt a hospital from the requirements.

Additional Frequently Asked Questions Regarding Requirements for Hospitals To Make Public a List of Their Standard Charges via the Internet

This post section includes Medicare’s posting of additional questions and answers for two separate CMS FAQ documents on Price Transparency

Q. Are Inpatient Rehabilitation Facilities and Inpatient Psychiatric Hospitals required to make public a list of their standard charges via the Internet?

A. Yes, this requirement applies to all hospitals operating within the United States.

Q. Are Critical Access Hospitals and Sole Community Hospitals required to make public a list of their standard charges via the Internet?

A. Yes, this requirement applies to all hospitals operating within the United States.

Q. Do the requirements apply to drugs and biologicals?

A. Yes, the current requirements apply to all items and services provided by the hospital.

Q. Is a hospital required to post its standard charges for drugs, biologicals, or other items and services that it provides if those standard charges are not reflected in its chargemaster?

A. Yes, it is the responsibility of the hospital to establish (and update) and make public a list of the hospital’s standard charges for all items and services provided by the hospital, including all drugs, biologicals, and all other items and services provided by the hospital.

CMS encourages hospitals to undertake efforts to engage in consumer friendly communication of their charges, including for drugs and biologicals, to help patients understand what their potential financial liability might be for services they obtain at the hospital, and to enable patients to compare charges for similar services across hospitals. A hospital is not precluded from posting additional price transparency information in addition to its current standard charges.

Q. In addition to establishing (and updating) and making public a list of the hospital’s standard charges for all items and services provided by the hospital, what hospitals are required to establish (and update) and make public a list of their standard charges for each diagnosis-related group established under section 1886(d)(4) of the Social Security Act?

A. All hospitals operating within the United States are required establish (and update) and make public a list of their standard charges for all items and services provided by the hospital. Under current guidelines, subsection (d) hospitals are additionally required to establish (and update) and make public a list of their standard charges for each diagnosis-related group established under section 1886(d)(4) of the Social Security Act.

The format for standard charges for each diagnosis-related group is the hospital’s choice. CMS posts information regarding inpatient charges for subsection (d) hospitals at https://www.cms.gov/ResearchStatistics-Data-and-Systems/Statistics-Trends-and-Reports/Medicare-Provider-ChargeData/Inpatient.html. Subsection (d) hospitals may, but are not required to, use this format with respect to the additional requirement that the hospital establish (and update) and make public a list of the hospital’s standard charges for each diagnosis-related group established under section 1886(d)(4) of the Social Security Act.

Q. Why isn’t a PDF considered machine readable?

A. We have defined a machine readable format as a digitally accessible document that includes only formats that can be easily imported/read into a computer system (e.g., XML, CSV). A PDF does not satisfy this definition because although it is a digitally accessible document, it cannot be easily imported/read into a computer system.

Q. What happens if a hospital does not make public a list of its standard charges via the Internet?

A. The hospital will not be in compliance with the law. In the FY 2019 IPPS/LTCH proposed rule (83 FR 20549), CMS sought comment on the most appropriate mechanism for CMS to enforce price transparency requirements. As indicated in the FY 2019 IPPS/LTCH PPS final rule (83 FR 41686), specific additional future enforcement or other actions that we may take with the guidelines will be addressed in future rulemaking.

Document sources – CMS website

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