AAMC Comments on Hospital Price Transparency Request for Information

The AAMC responded on July 21 (PDF) to the Centers for Medicare & Medicaid Services (CMS) request for information on hospital price transparency, in which the CMS solicited feedback on the accuracy and completeness of machine readable files. The AAMC supported the goal to increase health care price transparency for patients; however, expressed concerns with the administration’s current approach to price transparency, which is overly burdensome and costly for health systems and hospitals, does not enable patients to understand what they will actually pay for a health care service, and has resulted in widespread confusion for patients. The comments explained that determining accuracy and completeness of machine-readable file data is challenging given the multiple payment policies in health plan/provider contracts that can affect negotiated rates. The AAMC pointed out that the information that the insurer is required to provide to patients under the Transparency in Coverage rules may be much more relevant than any pricing information that providers would be able to deliver to the patient. For a patient, knowledge of their out-of-pocket costs, which depend on plan-specific cost-sharing requirements (such as deductible and co-payment amounts) is the most important information.