Hospital Price Transparency: New CMS Enforcement Measures, Increased Penalties, and Ensuring Compliance

This CLE course will guide healthcare counsel on the hospital price transparency rule and CMS' new enforcement measures. The panel will examine the rule, its requirements, and the implications of the enhanced enforcement. The panel will also discuss the rule's impact on a hospital's relationship with insurers and patients and offer best practices for compliance.

CMS' hospital transparency rule went into effect in 2021, but many hospitals disregarded the rule. Recently, CMS announced it has tightened enforcement of the rule. Under the new enforcement measures, CMS will require hospitals that violate the transparency rule to comply with all terms of a corrective action plan (CAP) within 90 days of CMS' request. Hospitals still must submit a CAP within 45 days from when CMS requests it.

Hospitals that fail to comply with the transparency requirements will face civil monetary penalties (CMPs) and publication of these penalties on the CMS website. Under the new enforcement measure, CMS will now impose automatic CMPs on hospitals that fail to comply with the CAP deadlines. If a hospital meets one but not both CAP deadlines, CMS will review the hospital's files to determine if there are violations. Those violations would be subject to an automatic CMP. Healthcare counsel should consider the legal and other risks as they work with hospitals to comply with the transparency rule.

Listen as our authoritative panel examines the hospital price transparency rule and CMS' new enforcement measures. The panel will discuss the rule, its requirements, and the implications of the enhanced enforcement. The panel will discuss the rule's impact on a hospital's relationship with insurers and patients and will offer best practices for compliance with the rule.