Ahh, December. In addition to merriment and festive cheer, ‘tis the season for looking ahead to a new year, new resolutions, but the same old hospital machine-readable files (MRFs). Right?

Well, not quite the same old, same old.

On the heels of the OPPS 2024 Final Rule, 2024 brings about some fairly sweeping changes to hospital MRF formats and requirements. The most significant changes to the actual MRFs themselves don’t go into effect until July 1, 2024, which is probably where most people stopped reading in the rule. Here’s an actual transcript of the most common train of thought while reading the Final Rule: “Something something schemas, something something algorithms, something something July, okay great, I have time.”

But wait! There’s more! The countdown is officially ON for a few key January 1st requirements that begin when we ring in the new year. Didn’t catch those on your first pass of the rule? Think of this blog as your holiday gift guide to the requirements.

Other New Hospital Price Transparency Requirements

In a move that definitely reads like a quiz to see who’s paying attention, the most time-sensitive dates are located at the very bottom of the CMS enforcement table:

Credit: CMS, page 1,462

From a broader compliance perspective, the key takeaway here is that CMS doesn’t plan to wait until July 1st to begin its 2024 hospital MRF compliance review. Furthermore, the Final Rule gives CMS permission to publicly share all its assessments, compliance actions, and outcomes on a website.

Currently, they’re only sharing a list of hospitals that received civil monetary penalties (CMPs), but its publications will expand in the new year. The message CMS is sending? Hospitals should already be getting their ducks in a row now.

So which ducks need to be in which rows, exactly?

Good Faith Effort

…not to be confused with Good Faith Estimates, of course, because we now live in a world where GFE can mean two things. *yells into acronym confusion*

According to the Final Rule, “each hospital must make a good faith effort to ensure that the standard charge information encoded in the MRF is true, accurate, and complete as of the date indicated in the MRF.” This is a more general requirement that is paving the way for an additional affirmation from hospital leadership on July 1st.

CMS stated its goal with this good faith effort is for hospitals to take clear, actionable ownership over reviewing their MRFs, regardless of if they created the files themselves or utilized a third party. Leadership must be confident in their data and publish in writing that they believe the MRFs to be true, accurate, and complete.

Txt File

The Final Rule requires “that the hospital ensure the public website includes a .txt file in the root folder that includes a standardized set of fields including the hospital location name that corresponds to the MRF, the source page URL that hosts the MRF, a direct link to the MRF (the MRF URL), and hospital point of contact information.” For hospitals that are part of a larger health system, CMS confirmed the .txt file can support multiple MRFs.

So what exactly is a root folder and how does one add a .txt file? The root folder is the location where files for a website are stored. In this case, specifically machine-readable files containing price transparency data.

CMS has made these tech specs available to assist with implementation, as well as this .txt generator tool to assist less technical staff in creating that .txt file. Swoon!

Similar to the .txt file, hospitals must also publish a footer link to a specific Price Transparency page. That footer link will help both CMS and patients as consumers identify a standard pathway to finding healthcare price information. It will also create a more uniform and predictable approach for third parties to aggregate MRF data and make data easily accessible. Alongside the .txt file, a footer link can go to a page that contains links to multiple MRFs.

Why are these specific requirements due so soon?

CMS confirmed the rationale for including the .txt file and footer link is to streamline and automate its process of retrieving MRFs. The Hospital Final Rule that’s currently in effect required that hospitals post their MRFs in a location on the website of their choosing that was easy to find, which, if you’ve spent time poking around half a dozen websites looking for MRFs, you’ll agree that some of them are pretty buried between non-intuitive headers or subpages. The presence of the .txt file should simplify that process both for individuals and CMS.

Should I panic?

No need to panic! There’s still time to be fully compliant by the upcoming deadline, which, one more time, for the people in the back, is January 1st.

This first wave of updates should not require an MRF overhaul, assuming the current MRF is complete and accurate. It’s an opportunity for hospital leadership to sync up, understand the data displayed in the current MRFs, shore up any missing data to show a good faith effort, and then make those files available for download in the specified locations.

If you’re looking for a price transparency partner for the new year, the Turquoise Health Hospital MRF Build Team (TQHMRFBT rolls right off the tongue but definitely wouldn’t sell on a t-shirt) has been hard at work providing instructions for hospital IT departments to ensure compliance with the new display requirements, both for the footer link and the .txt file. They’re around to answer any questions you may have.

Curious to learn more about our countdown clock to 1/1/24? Drop us a line.