Choosing Partners for Price Transparency

Too many options coming across your desk for Price Transparency assistance?  Here are 12 Tips to Selecting Business Partners.

Hospital teams know all too well that most every initiative, system change, or operational redesign comes with necessary partnerships with vendors or consultants. Today’s staffing is stretched thin in nearly every healthcare system. To combat that challenge, project-specific help is critical for large initiatives such as 2021 CMS Price Transparency mandates. Here are twelve tips to forging a partnership (or more than one partnership) to help your organization rapidly comply with soon-to-be effective rules.

Tip #1 – New Rules Mean New Solutions   

  • Even for companies with existing price estimator products or CDM display functions such as the ChargeAssist® Public Portal CDM web module, realize that pretty much everyone is creating new or expanded solutions for the 2021 expanded transparency requirements.
    • There was industry-wide hope that AHA’s lawsuit would change the CMS mandate, or the COVID-19 PHE may result in delayed implementation or penalties. CMS even as late as the last 8/11/20 Office Hours call noted that there is no plan to delay.
    • Even if deliverables are only in beta versions or examples, assess the solution-provider’s user-interface as well as the accuracy & comprehensiveness of the work products.
    • Ensure that new solutions will be live and ready well in advance of the 1/1/21 effective date.

Tip #2 – Look at Solutions from the Patient’s Perspective

  • For any Price Transparency deliverables or products that are facing patient-forward, evaluate the information from a patient’s perspective. (Or ask someone who isn’t a healthcare person for their opinion.) Assess the following:
    • Can the patient easily access and understand your estimation solution or public view chargemaster?
    • Are the shoppable services displayed through your estimator or alternative work product selected in a meaningful manner for the shopping patient?
      • Searching for an estimate means looking for the specific procedure or service the patient plans to receive. Building only 300 Shoppable services based on utilization trends will likely leave patients frustrated if a specific procedure isn’t available. 
    • Will the expanded 2021 machine-readable file of all charges and payer specific rates confuse the patient?  
      • We support the concept of a user-friendly searchable CDM despite CMS only asking for the machine readable file. This will improve the patient’s ability to find flat rate diagnostic tests beyond the ‘shoppable’ 300 items.
    • Can the patient easily obtain a realistic estimate of total charges for each of the Shoppable Services?
      • Ensure that you fully-understand how your vendor or consulting resources are creating accurate information.
      • Avoid patient complaints by ensuring estimates are based on extensive analytical information and not ‘ballpark’ estimates.

Tip #3 – Ensure the Solution Meets Regulatory Requirements

  • For content, accuracy, and compliance to the rule, ensure that the vendor’s methodology will result in meeting each of CMS’s 2021 mandated requirements.
    • Either be certain your team understands all nuances of the requirements by reviewing the rule, FAQs and transcripts from CMS, or has a very high trust level that your selected vendor has accurately and thoroughly interpreted it.

Tip #4 – Assess Timelines

  • Assess the company’s ability to meet the January 1, 2021 effective date based on their scheduling availability and when you plan to sign an agreement.
    • Ensure milestone-based date-driven timelines are in your agreement to avoid ‘not making it live’ on 1/1/21.
    • Confirm how vendors or consulting teams will project manage to ensure that your engagement is completed on time.
    • Confirm the frequency and depth of engagement status reporting.
    • Ensure you know YOUR milestone tasks as well as THEIR milestone tasks.
    • Confirm in advance the staffing/personnel involved in the project and review credentials or resumes of the vendor reps / consultants.

Tip #5 – Confirm Updates

  • Confirm whether the deliverable/product is going to be updated (either internally or by the vendor/consultant) with quarterly CPT-4/HCPCS code updates, future rate changes, new masterfiles, or other data elements that may be added to your hospital information systems applications.
  • Ask the vendor/consultants how they plan to address future Price Transparency regulatory changes and timelines to accommodate such changes.
    • For long term assistance or licensing, determine what is ‘in scope’ and what will generate additional cost.)

Tip #6 – Require Multiple Customer References

  • Ask to speak with several customer references.
    • Ask for customer references that have used the vendor for Price Transparency publication assistance or even those underway with current projects and willing to serve as a reference.
      • Ask for feedback on their experience with the vendor and the staff you will be working with.
      • For pricing assistance, confirm how the organization felt the results impacted their organization and if willing to share, what net revenue impact was gained.
      • Confirm with past customers whether they felt that the vendor provided defensible and reasonable pricing update strategies resulting in  both the financial improvements as well as assurance of the ‘defensibility’ of rate/price changes.
      • Confirm that the vendor’s contracting process was reasonable and easy to finalize.
      • Confirm that the reference customer felt that the vendor/consultant was able to meet HIPAA requirements and keep PHI safe.

Tip #7 – Look for a Match with Your Strategic Vision

  • Evaluate your organization’s strategic vision and determine whether the proposed software or engagement (and contract terms) reflect your long- term plans.
    • Evaluate whether a “Price Estimator” product is planned or whether your organization prefers to continue for some time with vendor/consultant assistance to maintain a Shoppable Services display option.
    • Determine whether a future strategic pricing engagement may impact the Price Transparency data and displays.
    • Expect that CMS requirements will change over time so strategies will most likely have to changes as well.
    • As Price Transparency gains momentum in the industry, expect that patient shopping experiences may also need to be improved.
      • Discuss your and the vendor/consulting firm’s long term vision.

Tip #8 – Ensure Data is Accurate, Defensible & Sound

  • Ensure that prices and CDM data are accurate, defensible, and sound. With expanded publication, expect scrutiny of your data by third parties.
    • Evaluate how your team can internally deploy your Charge Master Software tool (or other resources/staffing) for data assessment and clean up prior to beginning the Price Transparency work.
    • Decide whether a consulting engagement is needed to improve Chargemaster quality
      • Due to the 2021 effective date and available timeline, CDM Assessments may be more reasonable than Detailed CDM Reviews if your file needs to be analyzed.
      • Discuss how project scope may differ with various engagement options.
      • Consider the Consulting firm’s availability and engagement timelines for different types of projects.
      • Ensure the company reviewing the CDM for accuracy is skilled and experienced in the nuances of Charge Master management. Simply engaging a CDM Review by a less experienced firm may create more challenges than your hospital wishes to encounter at this late date.

Tip #9 – Confirm Detailed Methodology

  • Be sure you understand and agree to the detailed methodology vendors/consultants will use for 2021 requirements.
    • If there is any plan to reprice services or provide pricing strategies, this may take your Price Transparency initiative to an improved level of quality, but requires more time, effort and strategic work.
    • Ask the company how they perform pricing studies. Historic ‘optimization’ methods or ‘across the board’ approaches will likely run counter to your goals of defensible pricing under the upcoming era of transparency and may cause your rates to be challenged.
    • Confirm how the company plans to collaborate with your leadership, service line leaders, medical staff (if applicable) on pricing strategies.
      • Time involved for pricing decisions can be slowed dramatically by involving too many parties. However, buy-in from within your organization is essential for building trust in the organization’s rates that will soon be public.

Tip #10 – Confirm Your Staff’s Obligations

  • Determine how much of your staff’s time is going to be required for vendor options.
    • Ask for a detailed workplan prior to making decisions.
    • Obtain a tentative schedule at contract execution.
    • Evaluate the method of communication with the vendor/consultant.
      • If consultant travel is involved, decide whether it is feasible in today’s public health emergency.
      • Determine whether alternative communication methods be deployed such as web based working sessions.
        • If the later, confirm whether the company appears to have good technology for communications (internet speed, quality of audio and visual communications, etc.).

Tip #11 – Ensure Similar Business Philosophy with Partners

  • Confirm that the vendor/consultant follows a similar philosophy as your organization relative to public displays and CMS mandates. Red flags may include:
    • Suggestions to add layers of log-in requirements, passwords, signing waivers, lengthy disclaimers, or hiding display information within your website
    • Suggestions to limit the display fields counter to CMS requirements
    • Suggestions to camouflage your services with overly-simplistic charge descriptors or by only displaying overly-simplified data that prohibits the patient from understanding the published information
      • Be cautious with the CMS suggestion of ‘plain language’ in the shoppable services display. Ensure that any descriptor changes will not affect your future ability to audit, monitor, and maintain your masterfiles effectively.
    • Suggestions to list only select items and services in the machine readable file/display rather than all charges
    • Suggestions for the Shoppable Services selection criteria that is less than representative of primary charges your patients will likely be searching for
    • Suggestions for overly-complicated and complex displays that may cause patient confusion

Tip #12 – Create a Clear & Positive Patient Communication Strategy

  • Ask your selected vendor/consultant to help with a strategy to appropriately support, explain, and if necessary, defend your pricing strategies.
    • Debrief Administration and C-Suite staff of the price transparency mandate and hospital actions to comply.
    • Prepare a patient communication plan to answer patient questions on billed charges
      • Identify how patient questions shall be routed and logged.
      • Prepare key talking points and coach staff on customer care approaches relative to pricing concerns.
      • Conduct mock sessions to avoid having staff appear defensive or uncaring when patients have a complaint about billed amounts.
      • Develop an escalation plan for addressing continued patient dissatisfaction with explanations of pricing.
    • Develop a plan to orient hospital staff to Price Transparency so they feel confident in the organization’s rate setting methods.
    • Engage Medical Staff to serve as advocates to patients for understanding the nuances of price shopping and selecting a hospital provider.
    • Make Board members aware of the CMS requirements and your organization’s efforts.
    • Plan for communications with the press if you feel it is needed, and have a public /patient relations plan in the event of ‘rate expose’ articles.
    • Keep Compliance and Legal staff up to date with your efforts to comply with the regulations for increased transparency.

We hope these twelve tips are helpful for your plans to achieve 1/1/21 compliance to the CMS expanded Price Transparency mandate. In today’s Price Transparency fast track deployment, it’s more critical than ever to pick the right partners.

H&A solutions for transparency include not only our current functionality for the CDM Public Portal, but also expanded display options for 2021. We also endorse business partners’ in-depth claims and contract-based approach for creating a meaningful and consumer friendly “Shoppable Services” list, and happy to introduce them to your facility.  

Author: Rosemary Holliday, MHA, Managing Partner, Holliday & Associates/ ChargeAssist

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