Signaling that it is not done making changes to the existing hospital price transparency requirements, rules finalized by the Centers for Medicare & Medicaid Services (CMS) in November include several new provisions intended by CMS to improve accessibility, standardization and CMS’s enforcement of the machine-readable file (MRF).
Wisconsin hospitals have long been committed to transparency. While 14 hospitals across the country have been fined by CMS for non-compliance with the federal rules, not one hospital in Wisconsin has received a penalty. Several Wisconsin hospitals have received warning letters from CMS but have worked to resolve any issues to ensure they are complying.
Under the new rules, hospitals may have to make some changes to their MRF as early as Jan. 1, 2024. These changes standardize where on a hospital’s website someone can find the MRF to make it more accessible to third party vendors. In particular, as of Jan. 1, the new rule specifies that hospitals must:
- Include a link in the footer on the hospital’s public website, including on the homepage, that is labeled “Price Transparency” and that links directly to the publicly available web page that hosts the link to the machine-readable file.
- On the public website that hosts the MRF, include a .txt file in the root folder that includes all the following:
- The hospital location name that corresponds to the MRF;
- The source page URL that hosts the MRF;
- A direct link to the MRF; and
- A hospital point of contact.
In addition to the requirements that are effective Jan. 1, most hospitals will likely have to make changes to their MRF to conform to a new CMS template, new data specifications and a data dictionary, and new data elements. Some of these changes will have to be made by July 1, 2024, and others by Jan. 1, 2025.
To help hospitals understand what is required, WHA partnered with law firm Hall Render for a webinar that took place on Dec. 12. The webinar remains available for viewing and slides for downloading on Hall Render’s website here. You can also access this information on their website through the WHA On-demand Learning Center here under Links – “CMS Overhauls Hospital Price Transparency Rule: Key Takeaways and Action Steps.”