HFMA provides comments in support of its members on ‘tri-agency’ price transparency proposed rule

• HFMA provided comments on its members’ behalf  on the proposed health plan price transparency rule issued by the U.S. Departments of Health and Human Services, Labor and the Treasury.
• HFMA commented specifically on the provisions related to providing out-of-pocket estimates for insured patients.
• HFMA generally supports the final rule’s stated requirements, which are aligned with its price transparency taskforce report, but it’s letter makes specific recommendations to improve the quality of price estimates provided to health plan members.

HFMA provided comments on its members’ behalf in a Jan. 28 letter to the Centers for Medicare & Medicaid Services and Department of Health and Human Services on the proposed health plan price transparency rule issued by the U.S. Departments of Health and Human Services, Labor and the Treasury.

Based on our Price Transparency in Health Care report,  which is the result of a cross-industry taskforce convened by HFMA, HFMA commented specifically on the provisions related to providing out-of-pocket estimates for insured patients. While the provisions for providing out-of-pocket estimates largely followed our recommendations, we encouraged CMS to improve the final rule by taking the following steps:

Include quality measures in the information provided to members seeking estimates: Price alone is not enough to enable patients and other care purchasers to make an informed choice on providers. As noted in HFMA’s Price Transparency Task Force report’s definition of value, information on quality — comprising a range of factors, including patient satisfaction and experience, adherence to clinical standards and evidence-based medicine, and patient safety and clinical outcomes — is needed to ensure that a provider offers the desired level of value. Furthermore, given that many consumers associate higher cost with higher quality in healthcare services, HFMA’s members are deeply concerned that in the absence of quality data, transparent prices may actually increase spending. Therefore, HFMA’s members strongly recommend the tri-agencies delay the effective date of implementation of the final rule until they have worked with health plans and providers to develop a consensus methodology for displaying quality data related to the most common elective conditions and procedures for which health plans members could shop.

Ensure apples-to-apples comparison estimates: To ensure valid comparisons of provider price information, health plans and other suppliers of such information should make transparent the specific services that are included in the price estimate. Suppliers of price information should make sure that price estimates are accompanied by explanations of what services are included in such estimates, as well as the impact of differences in network status on such estimates, to help patients make valid comparisons among providers. For example, when comparing prices associated with receiving an imaging service, the patient should be informed whether the estimate includes both the facility cost and the radiologist’s fee. HFMA’s members support the proposed rule’s inclusion of an items-and-services list for bundled payment arrangements. Furthermore, our members agree with the proposed rule’s broad definition of bundled services to include both relatively narrow bundles (e.g., payments based on DRG) and expansive bundles (30-day episodes of care).

Include public payers in the out-of-pocket cost sharing estimate: HFMA’s members are deeply disappointed that the proposed rule’s requirements to provide out-of-pocket estimates do not extend to both Medicare and Medicaid beneficiaries. Therefore, we strongly recommend the final rule require CMS and state administrators of Medicaid programs to develop user-friendly price transparency tools for traditional Medicare and Medicaid beneficiaries.

For more information:

•  HFMA’s full letter on its members’ behalf. 
• A Healthcare Dive article, “Payers, employers protest price transparency rule as wrong-headed,” which shares other associations’ comments.