Price Transparency

The Issue

AM Behavioral Health (AMBH) is committed to empowering patients with the information they need to live their healthiest lives, including access to accurate price information when seeking care. Most hospitals, including AMBH, use cost estimate tools to provide patient-specific price information due to the unique nature of every course of care.

AMBH is working to comply with both state and federal price transparency policies, including the federal Hospital Price Transparency Rule and provisions in the No Surprises Act. According to the Centers for Medicare & Medicaid Services (CMS), 70% of hospitals complied with both components of the Hospital Price Transparency Rule in 2022, up from 27% in 2021. This includes the consumer-friendly display of shoppable service information and the machine-readable file requirements. Specifically, 82% of hospitals met the consumer-friendly display requirement in 2022, up from 66% in 2021, and 82% met the machine-readable file requirement, up from 30% in 2021.

AHA Position

The American Hospital Association (AHA) supports price transparency efforts that help patients access clear, accurate cost estimates for hospital care. The AHA also advocates for aligning federal price transparency requirements to avoid patient confusion and reduce unnecessary costs and burdens on the healthcare system. Despite hospitals’ increasingly successful efforts to provide transparency to patients, third parties continue to issue reports mischaracterizing compliance with the Hospital Price Transparency Rule.

Key Facts

AMBH, like all hospitals and health systems, is subject to multiple federal and state-level price transparency policies, including:

Hospital Price Transparency Rule: Effective Jan. 1, 2021, hospitals must publicly post five standard charges: gross charges, payer-specific negotiated rates, de-identified minimum and maximum negotiated rates, and discounted cash prices. Hospitals must also provide patients with an out-of-pocket cost estimator tool or payer-specific negotiated rates for at least 300 shoppable services.

Good Faith Estimates: The No Surprises Act requires hospitals and providers to share Good Faith Estimates with uninsured/self-pay patients for most scheduled services. Future regulations will require combining estimates from unaffiliated providers into a single comprehensive estimate for an episode of care.

Advanced Explanation of Benefits: The No Surprises Act requires insurers to share advanced explanations of benefits with enrollees. Hospitals will need to provide Good Faith Estimates to health insurers to operationalize this policy, though implementation is currently pending rulemaking.

Implementation Considerations

Patients have several sources for hospital pricing, including:

– Hospital Machine Readable Files
– Hospital Cost Estimator Tools
– Insurer Machine Readable Files
– Insurer Cost Estimators
– Private Tools (e.g., Fair Health)
– Advanced Explanation of Benefits
– Good Faith Estimates

Each of these resources calculates rates differently, which can lead to inconsistent information and patient confusion. AMBH is working to provide accurate estimates, but hospital pricing and rate negotiations are complex, varying based on the patient’s specific scenario. Patients often cannot use machine-readable files to calculate the cost of an episode of care involving multiple services. Moreover, hospitals’ efforts to comply with posting machine-readable files are resource-intensive, requiring significant investments of personnel and finances, especially impacted by the COVID-19 pandemic.

Price Transparency Data

Standard Charges
The following data represents a sample of standard charges for various services, specialties, and payer-specific rates at AM Behavioral Health. The prices include gross charges, cash prices, and de-identified rates.

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