Price Transparency 2022
Hospital Perceptions of CMS Regulation

Though Respondents See Value in Price Transparency, Most Cite Significant Challenges around Regulation Deployment

Many respondents feel the price transparency regulation is a step in the right direction toward the consumerization of healthcare and helps empower patients to oversee and control their own healthcare costs. However, the majority of survey respondents doubt the efficacy of the regulation as it exists today; of the respondents who anticipate that price transparency will moderately improve patient financial outcomes, over half believe the existing regulation needs additional clarification and federal guidance. There are concerns about cost, data accuracy, and patient adoption of pricing tools; some respondents worry about patients’ ability to understand the displayed pricing data, and today, most patients are unaware online pricing information exists or are unsure of how to interpret it. Additionally, respondents from smaller organizations worry price transparency will drive patients to larger hospitals for elective procedures and other shoppable services due to larger hospitals’ more competitive prices.

Many respondents are highly dissatisfied with two specific aspects of the regulation: the requirement to use machine-readable files containing pricing information and the requirement to broadly publish online a master list of rates. Respondents believe these requirements are onerous, citing difficulties with the software used to publish the pricing information. Some say the published rates mainly benefit payer and provider organizations instead of patients.

“The government’s current methods are not the best way to go about things. . . . The government wasn’t specific enough to make it easy for a market analyst to use the data. And they sure didn’t do something that patients could use. So the rules missed the mark entirely.” —Executive director of revenue cycle (anticipates moderate improvement to patient financial outcomes)

Most Respondents Say Significant Resource Investment Is Needed to Sustain Price Transparency

Though several respondents feel the regulation is well intended, they say it has been poorly executed. Many hospitals comply only because they are required to by law and because they want to avoid monetary penalties. Additionally, organizations struggle to find resources to help with compliance because of the financial burden of investing in a regulation that doesn’t provide a return on investment. This lack of investment can be problematic since knowledgeable and experienced resources are required to keep the pricing information accurate and compliant. Over the next year, respondents expect they will need to continually invest in people, processes, and technology to meet price transparency mandates. Over half of respondents report price transparency will continue to require a significant number of resources, saying the initial system build-out and the creation of individual templates for every service they wish to estimate a price for will be especially burdensome.

Confusion Abounds around Regulation Expectations and Needs

Respondents say the CMS regulation as it is written today is confusing; it is unclear what organizations need to do and where the regulation will go from here. Many organizations are not investing beyond the bare minimum requirements, and they don’t plan to do more until there is further clarity around the regulations and the expectations going forward. The second most-common challenge, cited by one-third of respondents, is lack of sufficient resources to remain compliant. Respondents are uncertain about the number and types of resources required today, much less the resources required in the future as price transparency rules evolve or are interpreted differently. Several respondents say their organization has had to bring in outside consulting groups to help navigate the requirements. Additionally, many have invested a lot of time into educating their employees about price transparency rules via webinars, classes, and resources for self-directed learning.

“Like everybody else, we are reactive, and we do what we can. But we are hesitant to do more than what is expected or written because the price transparency rules may change. We don’t want to invest in technology or third-party vendors that are ill prepared for changes.” —Business office director