Response to CMS Hospital Price Transparency Inquiry

This document is a technical report responding to the CMS request for information regarding hospital price transparency (HPT) data accuracy and completeness. It outlines potential external sources, such as the Transparency in Coverage (TiC) data and Medicare fee schedules, that can be leveraged to evaluate the quality of data in hospitals' machine-readable files (MRFs). The report discusses the limitations of TiC data, including its inability to validate Medicare Advantage and Medicaid managed care plan prices. It suggests that CMS could implement a consistent audit program, combining random and targeted audits to enhance compliance. The report emphasizes the importance of identifying outlier organizations and suggests that CMS prioritize auditing hospitals with significant price discrepancies. Additionally, it recommends standardizing reporting requirements to facilitate meaningful comparisons across entities and suggests focusing on validating completeness before accuracy to improve overall data quality.