As hospitals adjust to the price transparency rules that went into effect Jan. 1, 2021, Kelly Arduino, a healthcare industry leader for consulting and accounting firm Wipfli, is working with hospitals to help them comply with the rules.
She shared with Becker's the challenges hospitals are experiencing when it comes to price transparency and her best tips to align with the laws.
Editor's note: Responses were lightly edited for clarity and length.
Question: What is the biggest challenge hospitals are facing with the transition to the rules?
Kelly Arduino: Bandwidth to comply — hospitals don't have the staffing resources to manipulate the data in a way to meet the requirements. This includes those hospitals doing price transparency work internally as well as even preparing the data to work with an external consultant.
Increasing complexity of payer contracts — many contracts are moving to fee schedules from percent of charges, and these fees schedules don't conform to the pricing transparency requirements, resulting in significant work and judgment calls on the data.
Q: A hospital is asked by CMS to submit a corrective action plan for price transparency. What steps should they take to ensure their case is closed?
KA: Right now we don't have any clients that have received a corrective action plan. If you are working with an external consultant, make sure you know their record of compliance.
However, if you do have a corrective letter, document a plan of action with a target date for completion and maintain ongoing communication with a CMS representative specifically for pricing transparency.
Frequently visiting the CMS Pricing Transparency website for FAQs and for the latest and greatest interpretations of the rules will also help.
Q: What is your best tip to hospitals to comply with the rules?
KA: When developing the pricing list, have ample documentation on how it was put together, what data sources were used, and what assumptions and decisions were made to fill in any gaps — and everyone has gaps in their data.
Benchmark your organization against others to identify any missing key elements and to randomly compare pricing with other hospitals to identify any outliers.
Q: Have you seen more hospitals and health systems start to comply with the rules now that CMS is sending transparency notices?
KA: Yes, 2021 was a challenging year and many were hoping for perhaps a grace period or a suspension of the requirement altogether. However, corrective action letters certainly pushed hospitals into action, and pricing transparency has climbed up the "to do" list. If fines are enacted, then, this will likely push another round of conformity.