hospital price transparency

CohnReznick LLPCohnReznick LLPCohnReznick LLPCohnReznick LLP

HOSPITAL PRICE TRANSPARENCYUPDATE AND OUTLOOK

AAHAM National Webinar

Prepared July 15, 2021, updates in RED 7/21/2021

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TODAY’S SPEAKERCaroline Znaniec is a Healthcare Industry and Revenue Cycle Leader with CohnReznick LLP. Caroline has 25+ years of combined industry and consulting experience within the healthcare revenue cycle. She is a recognized industry speaker and author in such areas as coding and documentation, charge description master (CDM), charge capture, pricing, governance, technology, revenue integrity, compliance and revenue cycle transformation.

Caroline is a national member of the American Association of Healthcare Administrative Management (AAHAM) and member of the Maryland Chapter. She also an Advisory Board Member and Mid-Atlantic Chapter Leader for the National Association of Healthcare Revenue Integrity (NAHRI) and co-leader of the Maryland Healthcare Financial Management Association (HFMA) Electronic Health Record (EHR) Forum.

Also, follow Caroline on LinkedIn and Twitter for regular updates on price transparency initiatives, revenue cycle tips and advice. Caroline Znaniec

Caroline.znaniec@cohnreznick.comD: 410-463-9867

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TODAY’S WEBINAR OBJECTIVES• Expand understanding of the price transparency requirements and audit activities• Identify common errors in the publishing of data, displays and patient estimation tools • Review nuances of the rule that could lead to fines and other penalties • Identify steps to take to quickly comply with CMS requirements• Identify key stakeholder involvement in meeting and sustaining compliance• Understand where price transparency is headed, its impacts and what healthcare

providers and organizations should be thinking of next

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PRICE TRANSPARENCY REQUIREMENTS

Starting January 1, 2021, each hospital operating in the United States will be required to provide clear, accessible pricing information online about the items and services they provide in two ways:

• As a comprehensive machine-readable file with all items and services.• In a display of shoppable services in a consumer-friendly format.

This information will make it easier for consumers to shop and compare prices across hospitals and estimate the cost of care before going to the hospital.

CMS Hospital Price Transparency Pagehttps://www.cms.gov/hospital-price-transparency

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HAPPY NEW YEAR?!

RevCycle Intelligence, January 2021

CMS Hospital Price Transparency Page

Becker’s Hospital Review, January 2021 MedPage Today, January 2021

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POLLING QUESTION #1

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AND LATER ON … BREAKING NEWS!!

# of beds

% of revenue

CY2022 OPPS Proposed Rule

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WHERE DO WE STAND?

THE PRICE TRANSPARENCY COMPLIANCE INDEX. TEXAS PUBLIC POLICY FOUNDATION, FEBRUARY 2021

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POLLING QUESTION #2

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TOP ERRORS REMAIN CONSISTENT SINCE JANUARY

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REVIEWING HOSPITALS NATIONALLY

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EXAMPLE QUICK ASSESSMENT #1

Hospital Profile:

• Top US News & World Report• Recognized Academic• Large >1,500 beds• >60,000 discharges annually• TPS quality score below median• Dynamic EHR platform• Staffed faculty employed physicians

Anticipated Attribute

Inpatient Services – Room and Board

Inpatient Services - DRGs

Physician Professional Services

Standard Charge Billing Identifier

High Cost/Complex Pharmaceuticals

High Cost/Complex Supplies/Implants

Defined Cash Price/Discount

Accessibility

Reconciliation of Comprehensive File to Shoppables

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EXAMPLE QUICK ASSESSMENT #2

Hospital Profile:

• Regional Hospital• Suburban• Member of large health system• Medium >175 beds• >9,000 discharges annually• TPS quality score well below median• Dynamic EHR platform• Employed physicians (hospitalists)

Anticipated Attribute

Inpatient Services – Room and Board

Inpatient Services - DRGs

Standard Charge Components

Physician Professional Services

High Cost/Complex Pharmaceuticals

High Cost/Complex Supplies/Implants

Defined Cash Price/Discount

Accessibility

Reconciliation of Comprehensive File to Shoppables

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EXAMPLE QUICK ASSESSMENT #3

Hospital Profile:

• Critical Access Hospital• Rural• 15 beds• >450 discharges annually• TPS quality score not available

Anticipated Attribute

Inpatient Services – Room and Board

Inpatient Services - DRGs

Standard Charge Components

Physician Professional Services

High Cost/Complex Pharmaceuticals

High Cost/Complex Supplies/Implants

Defined Cash Price/Discount

Accessibility

Reconciliation of Comprehensive File to Shoppables

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POLLING QUESTION #3

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QUICK ASSESSMENT TAKEAWAYSHospital #1 - Northeast Hospital #2 - Southwest Hospital #3 - West

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TAKE OUR QUICK COMPLIANCE QUIZ

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POLLING QUESTION #4

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MANAGE YOUR RISKSFocus on • Publishing accessible files• Meeting standard charge requirements• Providing the basics – don’t over do it!• Communicating your efforts• Educating internally and externally• Assisting patients with estimates• Sustaining efforts

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OPPORTUNITY DWELLS IN PRICE TRANSPARENCY EFFORTS

Identify Capture Report Collect

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Revenue Integrity/ CDM

Compliance/ Legal

Reimbursement/ Managed Care

Clinical Operations

Revenue Cycle/ Analytics

Information Technology

Marketing/ Public Relations

THE PRICE TRANSPARENCY TEAM

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SUSTAINING PRICE TRANSPARENCY COMPLIANCE

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HOW MAY HOSPITAL PRICE TRANSPARENCY CHANGE HEALTHCARE?• Focus on the overall consumer experience• Increased pressure for hospitals to tie quality to pricing• Accelerated shift of hospital outpatient services to outside the hospital walls• Increased costs in emergent and inpatient care• Accelerated consolidation activity• Slowing of adoption for new technologies

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REFERENCES AND RESOURCESCMS Hospital Price Transparency Pagehttps://www.cms.gov/hospital-price-transparency

- Requirements- Frequently Asked Questions- Checklist

Email CMS Price Transparency Team MembersPriceTransparencyHospitalCharges@cms.hhs.gov

Read the OPPS Proposed Rule for CY2022 (start at page 731)https://public-inspection.federalregister.gov/2021-15496.pdf

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QUESTIONS

Caroline ZnaniecCaroline.znaniec@cohnreznick.comD: 410-463-9867