Recommendations for Hospital Price Transparency Standards

This document is a response to the Centers for Medicare & Medicaid Services' Request for Information on hospital price transparency. It outlines recommendations aimed at enhancing the accuracy and completeness of hospital pricing data. The response emphasizes the need for CMS to define key terms such as 'accuracy of data' and 'completeness of data' to ensure consistent compliance and reduce ambiguity. Concerns are raised regarding the potential for hospitals to submit inaccurate information due to compliance pressures and the limitations of the current data reporting format. The document suggests that CMS streamline reporting requirements and leverage existing data sources for validation. Additionally, it proposes improvements to the CMS validator tool and the use of Qualified Entities for standard pricing comparisons. The recommendations aim to improve the overall quality of the data reported under hospital price transparency regulations, thereby benefiting patients, payers, and regulators.