CMS’s Hospital Price Transparency regulations require hospitals to make public the standard charges of the items and services that they provide. In the CY 2024 Hospital Outpatient Prospective Payment System Final Rule (CY 2024 OPPS Final Rule), CMS finalized modifications to standard charge display requirements for hospitals and updates to the enforcement provisions to improve the transparency of the enforcement process. The effective date by which hospitals would be required to comply with some of these new requirements was delayed to either July 1, 2024, or January 1, 2025, due to comments submitted in response to the proposed rule. With the July 1, 2024, compliance date approaching, CMS has posted updated frequently asked questions (FAQs) on the Hospital Price Transparency website to help hospitals, consumers, and other stakeholders understand the new compliance requirements effective at the beginning of July.

Background on Hospital Price Transparency Requirement Updated Contained in CY 2024 OPPS Final Rule

Under CMS’s Hospital Price Transparency regulations set forth at 45 CFR part 180 et seq., hospitals are required to display standard charge information through both a machine-readable file and a consumer-friendly format.

In the CY 2024 OPPS Final Rule, CMS dictated the form and format that hospitals must use for the machine-readable file to increase standardization of the machine-readable file, such that hospitals must now conform to a CMS template layout, data specifications, and data dictionary. Further, per that same rule, hospitals must now place a footer at the bottom of the hospital’s homepage that links to the webpage that include the machine-readable file and also affirm in the machine-readable file that the hospital has included all applicable standard charge information in accordance with the requirements of 45 CFR part 180, and that such information is true, accurate, and complete as of the date of the file. Lastly, CMS also updated modifications to the enforcement provisions at 45 CFR 180.70 to improve CMS’s enforcement capabilities and increase transparency.

The CMS fact sheet regarding the hospital price transparency changes contained in the CY2024 OPPS Final Rule is available here.

Updates to the FAQ

Per the FAQ, the following requirements must be implemented by July 1, 2024, except where the compliance date is delayed to January 1, 2025 and noted below:

Machine-Readable File Information:

• Machine Readable File Date
• CMS Template Version
• Affirmation in the Machine-Readable File

Hospital Information

• Hospital Name
• Hospital Location(s)
• Hospital Address(es)
• Hospital Licensure Information

Standard Charges

• Gross Charge
• Discounted Cash
• Payer Name
• Plan Name
• Standard Charge Method
• Payer-Specific Negotiated Charge –Dollar Amount
• Payer-Specific Negotiated Charge –Percentage [of gross charge]
• Payer-Specific Negotiated Charge –Algorithm
• Estimated Allowed Amount (July 1, 2025)
• De-identified Minimum Negotiated Charge
• De-Identified Maximum Negotiated Charge

Item and Service Information

• General Description
• Setting
• Drug Unit of Measurement (January 1, 2025)
• Drug Type of Measurement (January 1, 2025)

Coding Information

• Billing/Accounting Code
• Code Type
• Modifiers (January 1, 2025)
• Setting

Coding Information

• Billing/Accounting Code
• Code Type
• Modifiers (January 1, 2025)
• Setting

The updated FAQ contains thirty updated frequently asked questions related to the implementation of the requirements effective July 1, 2024.

The updated Hospital Price Transparency FAQs can be accessed here.