Price Transparency Part 2 – Tactical Mistakes

As we begin the second year of expanded Price Transparency, the healthcare industry faces a multi-pronged public relations assault. CMS and the press are now identifying hospitals that have failed to meet CMS regulatory mandates. This special series of ChargeAssist® Update News focuses on root causes of the growing negative image of our industry relative to prices. This is part 2 of our three-part series on Price Transparency’s impact on hospital reputations and public relations.

Many hospitals have made the following tactical mistakes with Price Transparency 1) failing to fully adopt CMS regulations, and 2) utilizing practices that create barriers to data access.

Mistake #1: Late or Incomplete Price Transparency Publication

CMS and industry groups offered numerous educational programs throughout 2020 and 2021. Because of the one-year delay, it’s hard to argue that non-compliance is due to the lack of knowledge of the regulations.

Based on our internal monitoring of hospital web pages, it’s clear that many facilities still fall short of full compliance with regulatory requirements. The press has reported on hospital challenges such as complex payer contracts, difficulty compiling display information, vendor/consultant delays with deliverables, and in-house staffing shortages. Likewise, we understand that some hospitals have delayed creating transparency solutions awaiting Hospital Information System conversions or facility mergers that will impact Charge Master data and transparency publications.

We suspect the pace of adoption of Price Transparency will improve as CMS doubles down on its monitoring, reporting, warnings, and ultimate fines. Laws including the No Surprises Act, Transparency in Coverage, and Prescription Drug Benefit Reporting regulations will continue focusing on healthcare pricing over the coming years.

Inaccurate, incomplete, and slow adoption of Price Transparency place hospitals at risk of CMS actions, and can potentially damage an organization’s public image.

Mistake #2: Creating Roadblocks to Pricing Information

We believe that the perception of secrecy and excessive prices are two of the more significant public image risks. When hospitals (purposefully or inadvertently) make it difficult for consumers to find pricing information, CMS considers the actions inappropriate. CMS Proposed and Final Rules have identified Price Transparency roadblocks defined as: “any such practice that prevents accessibility.”

Common Price Transparency roadblocks include:

• Barriers to Access: Locating transparency information on hospital web pages has proven to be the biggest challenge to our research. CMS considers hidden or ‘buried’ transparency web pages as a roadblock to access. For example, we have located websites with required click-throughs, checkboxes, statements of agreement, captcha functions, disclaimer agreements, and even informational videos that must be completed to access machine-readable files.
• Limited Search Results: Another challenge is the lack of web search results when looking for price transparency postings. CMS expects hospitals to post information in a prominent manner and states that hospitals should avoid the use of “blocking” functions that limit access to hospital Price Transparency web pages.
• Delays with requests for information: Although the regulations now go far beyond providing a telephone contact alone, nearly every hospital provides a contact for questions about out-of-pocket costs, billed charges, and pricing. But just how quickly are calls returned, and how helpful are the contacts? To avoid making pricing even more confusing, hospitals need to create informational messaging on their websites, develop a triage protocol for patient questions, firm up policies on pricing/billing complaints, and ensure consistent team-wide messaging on prices.
• Incomplete Public Information: As we review hospital websites in 2022, we still see organizations failing to comply with all aspects of CMS regulations. Often, select information is provided while other mandated content is missing. Additionally, files often appear to be limited or incomplete, thus failing to fully-comply with CMS specifications.

The roadblocks above are likely to frustrate the shopping patient and leave a negative impression about the organization itself. Based on 2022 updated regulations, CMS can now call out blocking in their monitoring efforts. We suggest incorporating these CMS’ requirements in internal assessments:

• Users should be able to easily navigate to a hospital’s home web page to “click and search through pages related to patient billing and financing” to find the transparency information.
• Web pages for machine-readable files must be discoverable using simple internet searches using keywords such as hospital name plus ‘standard charges’, ‘price’, or ‘machine-readable file’.
• The machine-readable file must be accessible without barriers, and contents must be digitally searchable.

CMS discusses blocking methods that are problematic in the 2022 Final Rule: In April, 2021 the following article was released on actions by Congress, HHS, and ultimately, CMS related to blocking:

Price Transparency websites establish a public impression of hospitals. To avoid unintentional practices perceived as roadblocks, hospitals should review CMS guidance with their information technology departments, technical advisors, and others in charge of price transparency websites. Unless the industry’s Price Transparency websites become more widely accessible, CMS will most likely take a more prescribed and rigid regulatory approach.


Charge Management Take-Away

If you’d like to learn more on basic Charge Master Management processes and
techniques for improving your data and processes for Price Transparency, consider our 12 hour CDM Management Educational Program for Chargemaster Coordinators and Revenue Integrity Teams. Feel free to contact our Managing Partners, Rosemary Holliday at or Bud
Carroll at for a free consultative call to discuss your team’s specific Charge Management needs.

Holliday & Associates offers ChargeAssist® an HFMA Peer Reviewed™ Charge Master auditing and resource tool for easily auditing, collaborating, and maintaining Charge Master files. We also provide Charge Management Education and CDM Reviews by a team of credentialed clinical, coding and technical auditors.
Contact information: (800) 831-3323 | Web Site: |

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