January 19, 2021
When the clock ticked over to January 1, the new CMS price transparency rule came into effect.
While its implementation may have been largely overshadowed by other issues, the rule is in place and providers should be thinking about it.
Whatever your plans were for the rule beforehand – list your prices, implement user-friendly price estimator tools, ignore the rule for now and pay the fine – it’s worth considering how your approach can affect your reputation and, potentially, bottom line going forward.
We spoke with James Cervantes, associate vice president and leader of the price transparency work here at Jarrard Inc., and Prashant Karamchandani, director in the revenue cycle practice at The Chartis Group, about key considerations for providers now that the rule is off and running. Watch the video or read the transcript below.
PK: CMS has put out there the regulation around price transparency and wanting organizations – healthcare organizations – to start to list the rates that they have with insurance companies, as well as, they want patients to have visibility into what they’re charging and then what the reimbursement is and have an opportunity to do some comparisons.
And I think that’s the letter of the law and regulation. You have to have some level of viewing your shoppable services, but I think organizations that look at the regulation as just the only thing they need to do to be compliant are missing a key opportunity to use this regulation as a catalyst for change.
Which is aligning more to a more enhanced and better patient experience across the enterprise. And by that we mean starting to look at this to bring patients in. So if patients are coming to your website, looking at your rates, looking at your service offerings, you should be hooking them into a better workflow to continue them through that entire process.
Meaning, once they look at that information, they should then have an opportunity to identify what’s their actual estimate going to be for those services, start to think through, ‘How do I schedule for those services?’ And then if they can make payment or cannot make payments, start to engage in a conversation with the organization as to how they can address some of that.
So, yeah,there’s more you can do. And the more you can do with it is a different strategy. And it’s where folks should be spending that time right now – on that strategy – as well as complying with the letter of the law. So it’s a combination of both.
JC: So once you’ve created the program and you created your workflows and you operationalize that program, the next step is really to then communicate and share those tools and information with your patients and your community. So, how are you guiding patients to the front door of your health system or your hospital?
How are you directing them to the cost assessment or price estimator tool that you have? How are you reminding them of any financial or personal assistance programs that you have? Reminding them that if you’re providing estimates to procedures or surgeries, where to go for that information. So this is really in many ways a great time to remind patients and those that are seeking care at your organization of all the tools and information that they’ll have access to as they make their financial decisions about receiving care.
PK: I think there’s some key tangible benefits. So patient acquisition and patient retention, you’re going to instill trust within your patient population by providing this information out there and also continue having them coming back because you’ve created a whole new experience and level of transparency that they’re not used to today.
So it’s more than just listing pricing online, which is, I think, why we want to view it as a broader strategy. It’s really getting them into that better enabled and self-service workflow, which is how you want to be engaged with your patients and with all kinds of technology out there that you have, different things you can do to build that ecosystem. But I think that’s a key thing from an acquisition and retention perspective.
I think additionally, it helps from a patient financial experience for both not only the patient, but also for the organization. You can start to have more upfront conversations, easily, around expected out of pocket costs, how they might be able to pay for it, providing the mechanisms in which they can pay with all different types of technology, whether it be credit card or Google Pay, Apple Pay, the various things that are out there. That’s a key opportunity as well.
And then I think there’s a handful of patients out there – and it’s continuing to increase – where we’re seeing larger deductibles and out of pocket costs be placed on patients. So, we call under-insured and even the uninsured where you want to have a more upfront financial assistance conversation and creating that tightly knit workflow to help identify that through the price transparency and estimation will enable patients to better know, ‘can we afford it? Can we not? If we can’t afford it, what are my options?’ So they don’t feel reluctant to get care, but they feel like the provider organizations are really working with them to be helpful. And helping them find a solution so they can get care, but they also don’t create an extra financial burden on themselves.
JC: As providers share this information and communicate with patients. I think it’s really important to make it very clear and in a concise way using language that patients understand. So we’re talking a lot about price transparency. That doesn’t necessarily mean that price transparency needs to be the way that you refer to this program.
It’s really making sure that patients… it’s communicating very clearly all the tools and information and resources that they have access to. And for most patients that might just mean connecting them with your financial services team or your personal assistance program and having that really be a dialogue.
I think it’s important to make sure that the information is clear. It’s concise. You’re not using language that is a legal term that patients wouldn’t understand. So sort of putting it at their level and making sure that it’s just very clear and easy to access if they’re going through a website or if they’re calling the phone number to talk with someone.
PK: So I think there’s some key considerations you’re looking for. And some fall in the realm of the operations side of the house and some fall in the realm of technology and digitally enabling patients to have this experience. So first, I think it’s creating a strategy around the patient financial experience or the patient experience overall and using the price transparency component as a large initiative underneath it.
And then once you do that, you start to identify creating a much more refined and streamlined workflow for patients to enter into. So really it’s on an operational side, you’re mapping it out. And these are the functions that are going to hit scheduling departments, departments that do key revenue cycle functions around patient access.
So, pre-registration registration, insurance verification, et cetera, financial counseling, like we talked about. And then you have your component on the back end, which is the actual collections, which might happen at times. So you’re really looking at a more holistic view in terms of how you need to operationalize this.
And it’s more than just within the revenue cycle. If you’re a large provider organization, you need to get your clinics involved, your key departments involved, providers have to be integrally involved in these conversations. And then I think technically you need to evaluate your ecosystem and say, ‘within our core systems that we have today, can I do these things like provide an estimate? Can I do these things like collect payments ahead of time or pre-service based off of the estimate? And can I do it in such a way that’s engaging with the patient to enable a level of self-service and customization so it’s not a generic experience? And I think those are the key things. So, defining the strategy, working with those departments to create that operational workflow, but making sure that workflow is supplemented with the right technology, both within your organization – and that might be infrastructure-related – as well as more patient-facing to get them in there. But really, when you think about it, that means it’s more than just a revenue cycle issue or a clinic issue. We’re talking about several different departments working in an integrated fashion to create that seamless experience.