WSHA Provides Guidance on CMS 2019 IPPS Final Rule Transparency Requirement

November 29, 2018

WSHA recently sent a bulletin to hospital chief financial officers, government affairs staff, and legal staff regarding a new Centers for Medicare and Medicaid Services (CMS) requirement that all hospitals post their standard charges as reflected in the chargemaster. The requirement is effective January 1, 2019 and applies to all hospitals. Hospitals should consult with their legal counsel to make decisions regarding how best to comply with the requirements.

The 2019 IPPS final rule (pages 2135-2142) requires “hospitals to make available a list of their current standard charges via the internet in a machine-readable format and to update this information at least annually, or more often as appropriate.” The rule provides guidelines for an existing requirement from the Public Health Service Act.

The rule was finalized despite letters from the American Hospital Association (AHA), WSHA and other state hospital associations. The associations commented that charge information in this format would be confusing to consumers as it would not reflect their out of pocket costs. Despite these concerns, CMS is requiring hospitals to provide information for all items and services provided by the hospital based on the chargemaster. WSHA is recommending hospitals post the link to the information near other information, such as links to other pricing and transparency tools, information advising patients of their ability to request an estimate of charges and information regarding financial assistance (also referred to as charity care).

CMS provided a set of Frequently Asked Questions (FAQ) regarding the new requirements but is not expected to provide significant additional guidance prior to the start date. WSHA recommends hospitals make efforts to comply with the requirements as they are currently known. WSHA will continue to engage with CMS to offer feedback and gain clarification on the new guidelines and other federal price transparency efforts. (Andrew Busz,


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