PRA Submits 2023 OPPS Comments with Families USA
PRA and Families USA submitted public comments on the proposed 2023 CMS OPPS rule. CMS used the OPPS rule to promulgate the Hospital Price Transparency Rule, and has the opportunity to improve upon it this year through this Proposed Rule. We recommend that CMS strengthen the hospital price transparency requirements in the following crucial ways:
Increase Enforcement of the Hospital Price Transparency Rule and Remove the Penalty Cap. Given the continued vast noncompliance of the majority of hospitals, stronger, more timely enforcement is needed to enable consumers to realize the benefits of healthcare price transparency.
Collect, Use, and Share Standardized, Transparent Pricing Data. We recommend that CMS collect, store, and publish hospitals’ pricing data, and require uniform pricing data standards to enable both CMS to timely enforce the rule and technology companies to access and aggregate the data.
Require Attestation from Hospital Management that Pricing Data is Complete and Accurate. Attestation will ensure consistency, accuracy, and completeness of hospital price disclosures.
Align Policy and Enforcement Between Hospital Price Transparency and Transparency in Coverage. We recommend that CMS use its role as a regulator of both hospitals and coverage to align policy between these two important transparency frameworks, including by using hospitals’ and payers’ submissions to confirm the accuracy of data and inform enforcement efforts.
Eliminate the Price Estimator Tool Loophole. We recommend that CMS eliminate the price estimator tool in favor of actual, upfront prices that are binding, to hold hospitals accountable and protect patients from being overcharged.
Publicize Consumers’ Right to Upfront Healthcare Prices. We suggest that CMS educate healthcare consumers that they have a right to receive upfront prices in advance of receiving care.
Read the full comment letter HERE.