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HPS - CMS Charges Compliance (C3) Overview

published by Rick Louie

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Hospital Pricing Specialists LLC
CMS Charges Compliance (C3) Overview
Achieving simultaneous compliance and marketing enhancement.
A study in the August 2018 issue of JAMA Internal Medicine found that only 21 percent of hospitals had the ability to provide a complete hospital price estimate for a common procedure
01.
OVERVIEW
Hospital Pricing Specialists LLC is a 10-year old company that specializes in benchmarking hospital prices in order for hospitals to set market-defensible prices.  Over 600 hospitals throughout the United States utilize HPS hospital pricing reports. 

On August 2, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (CMS-1694-F)  specifically requiring hospitals by 1/1/19 to "make available a list of their current standard charges, including for diagnosis-related groups established under section 1886(d)(4) of the Social Security Act, via the Internet in a machine readable format and to update this information at least annually, or more often as appropriate."

In response to this mandate, HPS offers a robust, cost-effective solution called C3 (CMS Charges Compliance). Moreover, C3 allows hospitals to simultaneously comply with CMS and optimize their charges for a more favorable market position.


01b.
OVERVIEW
HPS takes a unique approach to constructing hospital price lists, in that all price lists show the target hospital's price in relation to the local market:


OURS
THEIRS
Baptist Health System
Expense Navigator
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quotes here.
02.
PROCESS
Define Market
Select local market competitor hospitals and calculate market prices.
Compare Prices to Market
Publish Prices via Secure Embedded Link
Once price comparison are approved, HPS creates web form with highlighted prices and link to download PDF of all CDM prices.
In healthcare, as in the rest of the economy, when price matters, consumers respond.

- Bill Simon, Former CEO of Walmart
Compare client hospital's Inpatient and Outpatient prices to market. Adjust prices to market and strategically display high-volume, favorably priced services.
03.
DEFINE LOCAL MARKET HOSPITALS
Local Market
Hospital price lists that do not show a hospital's price in relation to the local market are not meaningful to the average patient.

Patients know the approximate price to purchase a loaf of bread, but they have zero knowledge of the appropriate charge for a hip replacement.
HPS suggests a local market comparator group between 10-15 hospitals.

04.
COMPARE INPATIENT MS-DRG CHARGES
The CMS guidelines specifically say to compare charges of diagnosis-related groups established under section 1886(d)(4) of the Social Security Act. 

HPS calculates the client and market MS-DRG average charge, based on the latest adjudicated CMS claims data. HPS has identified 50 high-volume MS-DRGS and translated their descriptions into consumer-friendly descriptions.  Client chooses which MS-DRGs to display in the active price list 
DIRECT INPUT OF TRADITIONAL ALL-PAYOR INPATIENT CHARGES
Normal Newborn and C-Section charges are typically not found in the CMS claims.

HPS extracts the market charge for these services from HealthcareBlueBook and client directly inputs its charges for the same services.
04b.
05.
COMPARE OUTPATIENT CHARGES
HPS calculates the client's CPT outpatient charges and compares to the market.

HPS works with the client to suggest which outpatient services the patients expect to see pricing information. Client may update its final prices before publication.

HPS has identified 381 CPT codes that are frequently shown in hospital price lists.  Each of these 381 codes are grouped by category:  Emergency Department, Infusions, Injections, Laboratory, Occupational Therapy, Physical Therapy,  Pulmonary Therapy, Respiratory Therapy, Speech Therapy, and X-Ray and Radiological.
06.
CREATE HOSPITAL PRICE LIST
Place link on website that links to client's hospital price list, stored on HPS secure server.


07.
LINKED HOSPITAL PRICE LIST - Page 1 of 5
08.
LINKED HOSPITAL PRICE LIST - Page 2 of 5
09.
LINKED HOSPITAL PRICE LIST - Page 3 of 5
10.
LINKED HOSPITAL PRICE LIST - Page 4 of 5
11.
LINKED HOSPITAL PRICE LIST - Page 5 of 5
[Click Here to Download John Muir Medical Center-Walnut Creek's Complete Chargemaster in Machine Readable Format]

RESULTS
Ambulatory Surgery Centers showed a median 50% increase in patient volume after publishing their prices on the internet.
https://www.ncbi.nlm.nih.gov/pubmed/29712614
HPS is the market leader in providing a robust, cost-effective compliance solution for publishing hospital charges, within its CMS Charges Compliance (C3) tool.

Moreover, the C3 allows hospital senior management to actively monitor charges with timely data and be SWAT-team responsive to negative marketing pieces asserting high charges. We encourage all PR responses to high charges to include comparisons to local market charges.
      
                                 Email [email protected] 
                                 for more information on C3.               
WWW.HOSPITALPRICINGSPECIALISTS.COM