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Price Transparency Compliance

Price Transparency Compliance July 12, 2022
Is price transparency on your compliance work plan?  If it isn’t, there may now be 1,097,500 reasons to consider adding it!  That is the dollar amount of civil monetary penalties which CMS collectively seeks from Northside Hospital Atlanta and Northside Hospital Cherokee according to notices of imposition of CMP issued to those facilities on June 7, 2022.
As we are all aware, the objective of the hospital price transparency requirements is to enable consumers to understand and compare prices for hospital services before such services are received.  More specifically, 45 C.F.R. Part 180 requires hospitals and health systems to comply with two primary requirements.  Simply stated, those requirements are to post and periodically update a machine-readable file containing prices for all items and services provided (both inpatient and outpatient), and to post a “consumer-friendly” list of 300 shoppable services. 

Various industry news sources also published earlier this year articles highlighting a price transparency compliance review performed by of 1,000 hospital websites.  That review was concluded on January 28, 2022, with findings suggesting that 143 of 1,000 hospitals were then in compliance with the fundamental requirements of the price transparency rule.  That review further reflected that the most common area of noncompliance was in the posting of a complete machine-readable file of standard charges.  While rates of observed compliance were higher for the publication of a price estimator tool for shoppable services, only 28% of hospitals were categorized by the review as having posted the 300 most common services in a “consumer-accessible” manner. 

What does this all mean for compliance professionals in the health system and hospital space?  The Biden administration articulates ongoing support to the promotion of competition and pricing transparency in healthcare. CMPs can be imposed at a minimum of $300 per day for hospitals of less than 30 beds with an additive penalty of $10 per day/per bed for larger facilities. Preliminary desk reviews can be performed by CMS using a minimal degree of resources. Our takeaway from this is that the arena of price transparency is ripe for additional enforcement actions to occur.  Additional information may be located at:
Semi Annual Compliance Report 2022 —
Enforcement Actions | CMS
Hospital Price Transparency Frequently Asked Questions (

HBE’s team of experts is available to assist you with audits of your price transparency compliance as well as policy and procedure development and customized education and training.  

DISCLAIMER:  This newsletter contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations are general and specific questions should be directed to professional counsel.

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