Remediating Pricing Transparency Issues for a Critical Access Hospital

Since January 1, 2021, the Centers for Medicare & Medicaid Services’ Hospital Pricing Transparency Rule has required every hospital operating in the U.S. to publish an annual list online of the hospital’s standard charges for items and services provided in two ways:

  1. A comprehensive machine-readable file
  2. A consumer-friendly display including at least 300 shoppable services

Hospitals that fail to provide this information will incur CMS violation notices and fines of $300 per day for hospitals with 30 or fewer beds, and a penalty of $10 per bed per day for hospitals with a bed count greater than 30.

In November 2022, our client, Alleghany Health — a critical access hospital in Sparta, North Carolina — received a Hospital Price Transparency Warning notice from CMS, stating the hospital was noncompliant with requirements. Alleghany received this violation notice despite their intention and effort to comply by using a free service to post their shoppable services.

Unfortunately, like many other CAHs, they struggled to identify 300 unique shoppable services to post on their website. CMS gave the hospital 90 days to remediate issues in both their comprehensive machine-readable file and consumer-friendly list of shoppable services.

Stroudwater’s Pricing Transparency Expertise

For over three years our team has partnered with CAHs and other facilities to create fully compliant pricing transparency files.

Using our expertise in pricing transparency and the rural marketplace, we worked with Alleghany’s team to identify 300 services for inclusion in the listing. During a previous engagement, we had also provided resources and support to analyze Alleghany Health’s chargemaster. This knowledge was key in gathering the necessary information to create the comprehensive machine-readable file required by the new law.

We used our internally developed model to create Alleghany’s pricing transparency files and collaborated with the hospital’s team to identify ancillary charges and other services included with the individual 300 shoppable services. Alleghany also identified reimbursement rates for their contracted payors.

As a result of our partnership, Alleghany received all of the necessary files to post on their website and meet the remediation requirements identified in the violation notice. While the hospital had 90 days to resolve the issues for CMS, the project was completed in less than 60 days.

“As with small rural hospitals, Alleghany Health does not have in-house expertise to support complex initiatives such as the CMS Pricing Transparency requirements,” said Alleghany Chief Administrative Officer, Kathryn Doby. “Amy Graham with Stroudwater responded immediately to our call for assistance and worked with us tirelessly to address the reported violation. With her constant guidance and support, we were successful in correcting the issue and having a posting that meets CMS’s requirements.”

Learn more about Stroudwater’s pricing transparency services for hospitals.