Responses to our CY24 OPPS Final Rule Webinar on Hospital Price Transparency

During our 2024 Price Transparency Webinar we had several excellent questions!

Here are our answers.

1. Does the “estimated allowed amount” ONLY include the payer portion or does this also include the patient responsibility?

   This would be the full allowed amount – inclusive of patient responsibility

2. For many supply items, the payment is bundled.  In the payment methodology section, we do not have a bundled payment selection, so we are forced to use “Other”, then since it is a bundled payment, then we would use 99’s for the estimated reimbursement amount?

   We believe displaying payment at a grouped encounter level (MSDRG for inpatient, primary APC for outpatient) will resolve this issue by including any item or service that is bundled without separately payable lines.  This will also further emphasize how payment is always derived at a claim level.

3. Has CMS provided any specifications for/an example of the txt file in the web site root directory yet?

   Not to date, however, there is an open request for this on the technical github site, so, we would anticipate one being available soon.

4. If our hospital’s main corporate website has a “global footer” is it ok to only have this one footer hyperlink to all of our 8 individual facilities webpage? Or do we need to have each individual facility have their own footer?

   You could consider creating a system price transparency webpage with access to all 8 facility MRF files.  Then, the system “global footer” could access any of the 8 files.

5. Are you going to email out the slides, or are they available on the website?

   Slides and additional resources are now available on the website.

6. Does CMS have specific requirements regarding how many clicks from the footer to get to the MRF file itself?

   The footer link should link “directly to the publicly available web page that hosts the link to the MRF.”  So, the link should lead directly to the page where the MRF is posted.

7. Will this apply to Critical Access Hospitals?

   Yes

8. Have you seen any further clarification on the definition of “Employed Physician” and inclusion of pro fee pricing?

   No, CMS chose not to formally define “employed” in any final rule to date.

9. Change to allowed amount?  Payer’s Allowed Amount isn’t always accurate, we see overpayments and underpayments. Has this been addressed or considered?

   It has not been addressed, however, in the verbiage about the ability for a hospital to use 835 data to calculate this field, CMS says it recognizes this value will include “any adjustments made to the claim, such as denials, reductions, or increases in payment.”