Perspectives on a selected key topic                                                                                 February  /March 2021

2021 ACO Directory
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Now that the Price Transparency Rule has been in effect since the start of the year, and survived a D.C. Court of Appeals challenge, what are your thoughts going forward: are there still many hospitals dragging their feet? Is any meaningful transparency occurring? Are there any stakeholders notably capitalizing on the opportunity so far? Will the rule ultimately have significant impact for stakeholders?”
 
David Wofford and Ken Steele
 David Wofford

David Wofford
Associate Principal
ECG Management Consultants


Ken Steele

Ken Steele
Principal
ECG Management Consultants
  ECG has been asking the same questions, and over the past few weeks we’ve conducted research in many metropolitan areas across the US to see how hospitals are responding to the transparency rules. The new rules have only recently gone into effect and some hospitals are still in implementation mode, which may explain why we’re seeing a mixed bag in terms of the information being made available.

Nonetheless, if a hospital hasn’t yet published all the required information, we would not characterize it as foot-dragging. It must be remembered that the requirement could not have come at a more inopportune time given the COVID crisis, and with very little response time at that. Also, there is a lot of uncertainty regarding what the rule actually requires and whether those requirements will change under the new Biden administration. It also appears that some organizations may be waiting to see what others are doing before implementing their reporting strategy.

While the results are very preliminary, we do think that transparency requirements will have a meaningful impact in the industry. Already we are seeing that the press, including some national publications, has taken notice of this newly-available information and highlighted hospitals that have particularly high prices. We are also seeing interest among some hospitals in using this information to help them gauge their prices relative to the market, both to help them compete more effectively with other hospitals and to inform their negotiations with payers.

In its current form, the transparency rule leaves a bit to be desired, but like so many CMS programs, it will likely be refined over time. To the extent that the data becomes both more reliable and comparable across facilities, it will influence consumer behavior. We are particularly interested in seeing the response to the transparency in coverage rule, which applies to payers. We believe the payers are in a much better position to provide consumers with actionable information that allows comparison shopping across multiple hospitals, which could be a real game-changer for the industry.
 
Chris Sukenik and Kevin Sears
 Chris Sukenik

Chris Sukenik
Principal
BDC Advisors


Kevin Sears

Kevin Sears
Director
BDC Advisors
  The Hospital Price Transparency rule has been in effect since the beginning of 2021. Last year, there was much discussion around the rate of hospital compliance with the rule and the impact of releasing this information.

Early results are in. The majority of hospitals are complying with at least one of two requirements for the price transparency rule (consumer shoppable services data and charge master-level data). A recent study of 1,000 hospital websites completed by Guidehouse found that 70% of hospitals complied with at least one of the two requirements. 25% of hospitals had posted both required files, 60% posted the consumer shoppable services file and 48% completed the charge master-level disclosure.

Among hospitals that have not released their prices, common explanations include the resource burden of this effort amidst COVID-19 and concerns related to strategy and competition. We expect hospital compliance to increase. The remaining roughly 30% of hospitals that have not yet posted will likely find themselves under increasing pressure to comply.

With this marked increase in availability of pricing data, we are observing a series of important impacts:

Increasing Media Attention: As expected, media stories focused on differences in hospital pricing are starting to trickle out. A recent Wall Street Journal article titled “How much does a C-Section Cost? At One Hospital Anywhere From $6,241 to $69,584” gives you a sense of the message. We expect many similar news stories will be forthcoming.

Rising to The Data Challenge: To set the stage, there is a significant amount of information which has been released in non-standard formats. The data files are large, health system-specific and will require substantial time and effort to extract all the insights they have to offer.

Intensifying Managed Care Negotiations: Despite data realities, price transparency is already impacting negotiations between health systems and health plans. For a health plan, it is a relatively easy exercise to analyze a health system’s charge master-level file and compare how it is reimbursing the health system compared to competing health plans (all of the data is in a single file). Similarly, health systems are trying to do the same but need to access and integrate multiple health system data files to execute these comparisons.

Effects on Patient Decision Making: Many health systems chose to comply with the shoppable service requirement by offering a patient liability estimator which allows patients the opportunity to price shop. However, we expect the more significant impacts on patient decision making will occur once the health plan disclosures required by the Transparency in Coverage rule start to take effect next year and health plan pricing tools are coupled with patient incentive payments for choosing high value providers.

Expanding Focus on Strategic Pricing Efforts: Health systems and health plans are increasingly motivated to develop new pricing strategies. Motivation is not hard to find--hospital disclosures are now required, managed care negotiations are intensifying and health plan disclosures are set to take effect starting next year (and escalating in subsequent years). Many organizations are deciding that the best time to develop their pricing strategy for an increasingly transparent market is now.
 

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