A RESPONSE TO THE CY24 OPPS PROPOSED RULE (CMS-1786-P) FOR UPDATES TO HOSPITAL PRICE TRANSPARENCY REQUIREMENTS Download the pdf here! Background The CY24 OPPS Proposed Rule contains additional information and requirements regarding hospital price transparency. The proposed changes would build on transparency requirements previously established through the following rules: FY19 IPPS Final Rule:...

Negotiation Skills: Impact on Health Plan Terms A clear sense of current market trends, cost of care, and demonstrated efficiencies that reduce cost are essential elements of contract negotiation preparations. Negotiation leverage, in terms of hospital control, comes from several sources. The most recognized driver is market power based on geographical area or demographic factors. However, hosp...

How hospitals can create cost advantage where product differentiation is not present A challenge exists in finding accurate comparative data for bundled-payment arrangements, such as total hip replacement Cost advantage is necessary when a business is perceived as providing the same products or services as its competitors. In the eyes of many major healthcare payers, hospital services are not pe...

A RESPONSE TO THE CY22 OPPS PROPOSED RULE (CMS-1753-P) FOR PROPOSED CHANGES TO REQUIREMENTS FOR HOSPITALS TO MAKE PUBLIC A LIST OF THEIR STANDARD CHARGES Provided by: Cleverley + Associates The CY22 OPPS Proposed Rule contains additional information and requirements regarding hospital price transparency. The proposed changes relate to current requirements found in CY 2020 OPPS Final Rule on Tra...

Testing and Analysis to Prepare for Payment Changes Two areas that effect the impact of contract changes include how payers define categories and services and hierarchies of payment. A substantial provider-payer contract is nearing the renewal period. The payer initiates proposed changes to current payment terms, but the provider already has in mind specific outcomes desired for the upcoming co...

Implementing fixed-fee provisions would not remove the factors that drive price increases, nor would it reduce administrative hassles or decrease risk. Advocates of replacing percent-of-charge (POC) contract provisions with fixed-fee payments as a restraint on hospital costs overlook that hospitals wouldn’t be able to reduce their charges except in the unlikely event that fixed-fee payments exc...

A Response to the CY20 Opps Proposed Rule (CMS-1717-P) For Increased Price & Payment Disclosures 1) BACKGROUND The CY20 OPPS Proposed Rule contains additional information and requirements regarding hospital price transparency. The proposal, which can be traced to guidelines provided in the Affordable Care Act, primarily follows several recent important government communications regarding th...

A Response to the CY22 Opps Proposed Rule (CMS-1753-P) For Proposed Changes to Requirements for Hospitals to Make Public a List of Their Standard Charges 1. Background The CY22 OPPS Proposed Rule contains additional information and requirements regarding hospital price transparency. The proposed changes relate to current requirements found in CY 2020 OPPS Final Rule on Transparency (CMS-1717-F2...