Overview

In 2019, The Centers for Medicare and Medicaid Services (CMS) introduced price transparency requirements for hospitals. The price transparency landscape as we know it today began on 1/1/2021 when hospitals were first required to publish machine-readable files (MRFs) containing, among other required fields, 5 types of standard charges:

• Gross Charge: Charge for an individual item or service reflected in the hospital’s chargemaster (i.e. list price)
• Discounted Cash Price: Charge for an item or service administered by the hospital to a patient who will pay in cash or a cash equivalent
• Payer-Specific Negotiated Charge: Charge negotiated with a third-party payer for an item or service
• De-Identified Minimum Negotiated Charge: Lowest charge a hospital has negotiated with all third-party payers for an item or service
• De-Identified Maximum Negotiated Charge: Highest charge a hospital has negotiated with all third-party payers for an item or service

As of 1/1/24, MRFs must be located in a specific footer location on each hospital website, be free to access, and updated annually.

In 2023, CMS announced additional requirements to bolster the data and formatting of MRFs. The full list of required fields is detailed on github and is the basis for MRF generation in 2024 and beyond.

To be fully compliant with the 2024 final rule, hospitals or MRF generation vendor partners will need both claims data and full contracts to create a comprehensive and complete file.

This repository contains documentation of Turquoise's full understanding and approach to MRF generation. Although CMS has been actively responding to clarifying questions on github, a number of nuanced rate types and contract provisions remain open to interpretation. By publishing our rationale and decision-making processes, we hope to encourage further clarification around murky requirements to ensure all hospitals have a comprehensive tool kit to achieve full compliance.

External Resources

CMS Hospital Price Transparency Resources

2020 Hospital Final Rule - full text

2024 Hospital Price Transparency Final Rule - full text

CMS Hospital Price Transparency github

Turquoise Health TQU Hospital Price Transparency Hub

Questions? Reach out to the Turquoise team!