June 25, 2018
Re: CMS-1694-P Seema Verma Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
PO Box 8011
Baltimore, MD 21244-1850
Re: Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2019 Rates; Proposed Quality Reporting Requirements for Specific Providers; Proposed Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (Promoting Interoperability Programs) Requirements for Eligible Hospitals, Critical Access Hospitals, and Eligible Professionals; Medicare Cost Reporting Requirements; and Physician Certification and Recertification of Claims
Dear Administrator Verma:
On behalf of the undersigned group of medical professionals and associations, we appreciate the opportunity to comment on the issue of price transparency and the request for information included in the “Requirements for Hospitals to Make Public a List of Their Standard Charges via the Internet” section of the fiscal year (FY) 2019 Inpatient Prospective Payment System (IPPS) proposed rule. We recognize CMS’ efforts to better understand the costs of health care and improve price transparency and accountability for patients and would like to respond directly to some of the questions posed by CMS. To better inform your request for input, our responses that follow for the most part address medical care associated with the professional services delivered to Medicare beneficiaries by our specific hospital-based specialties, rather than the entire health care delivery system.
Section 2718(e) of the Public Health Service Act requires hospitals to establish and update a list of the hospital’s standard charges for items and services provided by the hospital. While CMS has issued guidance on this requirement in the past, the agency remains concerned that “challenges continue to exist for patients due to insufficient price transparency. Such challenges include patients being surprised by out-of-network bills for hospital-based physicians, such as anesthesiologists and radiologists, who provide services at innetwork hospitals, and patients being surprised by facility fees and physician fees for emergency room visits.”
Therefore, CMS is proposing to require hospitals to make available a list of their current standard charges via the Internet and update it at least annually. CMS is also considering other potential actions and requests comments on a number of issues that would help advance their “objective of having hospitals undertake
efforts to engage in consumer-friendly communication of their charges to help patients understand what their potential financial liability might be for services they obtain at the hospital, and to enable patients to compare charges for similar services across hospitals.” Specifically, CMS includes six questions in the proposed IPPS rule, which again, we are grateful for the opportunity to respond to.