We understand many of you are working on being compliant with the IPPS FY 2019 Final Rule Pricing Transparency requirements. You have likely read the most recent additions to the CMS website for Pricing Transparency—specifically, the FAQs and AFAQs.
At this time, Eide Bailly can provide guidance based on what is available from the rule as well as the FAQs/AFAQs. We have received many inquiries, such as “are RHC charges to be published?” “What about Drugs and Supplies?” “How is this really helping the patient?”
Here’s what we can state based on what we have seen in the afore mentioned guidance as well as the most recent American Hospital Association (AHA) Advisory:
We will continue to track pricing transparency and guidance from CMS as things develop.
The following are additional considerations that may help you in deciding if services must be posted as part of this requirement:
Eide Bailly is suggesting clients look towards using this guidance as an opportunity to put a more strategic spin on charging methodologies, chargemaster, pricing and transparency. Posting the charges is a good first step. We are recommending using this as the kick-off to asking questions regarding your charging strategy, such as “when was the last time we looked at our chargemaster and the surrounding policies and procedures?” “Are we actually capturing the charges we have in the chargemaster?” This is something that can be acted upon with a thoughtful plan and timeline.
Although there is still uncertainty, what we do know for certain is pricing transparency is here to stay. Organizations need to formulate a plan that goes beyond the posting of their standard charges if they want to stay on the right course.
If you have any additional questions regarding this, feel free to contact Amy Tepp, Partner, Director of Revenue Cycle Services.