Yes, there has been additional guidance released from CMS and the American Medical Association (AMA). As a quick recap, in the 2019 IPPS/LTCH Final Rule, CMS finalized their proposed update to the guidelines that effective January 1, 2019 hospitals will be required “to make available a list of their current standard charges via the Internet in a machine readable format and to update this information at least annually, or more often as appropriate.”
In early December CMS released the document, Additional Frequently Asked Questions Regarding Requirements for Hospitals to Make Public a List of Their Standard Charges via the Internet.
This FAQ document clarifies the following:
- What hospitals this requirement applies to,
- If drugs and biologicals are to be included,
- Why a PDF isn’t considered machine readable, and
- What hospitals are required to post standard charges for each diagnosis-related group (DRG).
Additionally, the question is posed regarding what will happen if a hospital does not comply with this requirement. CMS answer is to reiterate “as indicated in the FY 2019 IPPS/LTCH PPS final rule (83 FR 41686), specific additional future enforcement or other actions that we may take with the guidelines will be addressed in future rulemaking.”
The American Medical Association has also posted the following statement on their website:
Use of CPT® codes when complying with 2019 IPSS/LTCH final rule
“Organizations that have a valid and current CPT license for their chargemaster (which typically is a component of a revenue cycle management system) are permitted to post their chargemaster for the limited purpose of complying with the 2019 IPSS/LTCH final rule, effective Jan. 1, 2019 (i.e., solely to the extent necessary to make available a list of their current standard charges via the internet in a machine readable format and to update this information at least annually, or more as appropriate). Organizations that do not have a current license for their revenue cycle management system which uses CPT content, please submit a CPT Licensing Application to begin the process.”
Link to CMS October FAQs: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/AcuteInpatientPPS/Downloads/FAQs-Req-Hospital-Public-List-Standard-Charges.pdf
Link to CMS’ December Additional FAQs: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/ProspMedicareFeeSvcPmtGen/Downloads/Additional-Frequently-Asked-Questions-Regarding-Requirements-for-Hospitals-To-Make-Public-a-List-of-Their-Standard-Charges-via-the-Internet.pdf
Link to AMA Use of CPT® post: https://www.ama-assn.org/practice-management/cpt/cpt-licensing-health-care-delivery-organizations