Much has been said and written to summarize the 2024 CMS Proposed Rule, but we wanted to ask some best and brightest boots on the ground for their opinions. We assembled a brain trust of the following:
Adam Geitgey, CTO
Joey Plater, Solutions Engineer
Paul Zuradzki, Data Engineer
Ryan Kim, Product Manager
All four have spent years working in MRF data, so we were curious how they see their day-to-day work changing if the Proposed Rule is finalized.
Why are tech folks buzzing over the Proposed Rule?
Adam Geitgey, CTO
Data ubiquity. A standard format makes accessing the data much easier for all parties. This problem has plagued hospital price transparency since the initial Final Rule went into effect on 1/1/21 with no standard schema. The variation in MRFs made it exceedingly difficult for researchers and third parties to aggregate the data in mass, and it’s clear from the Proposed Rule that it was hard for CMS to aggregate the data and enforce compliance themselves.
Paul Zuradzki, Data Engineer
Can I give two answers? (Editor’s Note: Always!) First, we will have more structured data on formulaic payment methods. Right now I’m specifically thinking of percent of charge methodology, per diems, and variations of both, such as, “X per diem for days 1-2, Y percent of charge for days >3.”
Second, better metadata. We’ll know what the freshest data is since the Proposed Rule requires hospitals to include the file version and most recent update date. We’ll also have a more structured approach to associating pricing data with individual hospitals. Mapping and maintaining affiliations of individual hospitals to health systems should get easier since hospitals will have to clearly identify hospital names directly within the MRFs. Plus, hospitals must include a root .txt file to associate a hospital name with a specific MRF file and supply the actual download URL.
Joey Plater, Solutions Engineer
One additional metadata improvement: Hospitals must include that standard link to the MRF Paul mentioned in the hospital website footer to improve searchability and web crawling for programmatic retrieval. As much as I enjoyed poking around various hospital websites to find MRFs, this will save a lot of time and a lot of mouse clicks!
What components of your job are improved by the Proposed Rule?
Paul Zuradzki, Data Engineer
Data retrieval should be noticeably easier. CMS proposed that a .txt file be stored in the root of the hospital's site and standard footer link. Although this still requires data aggregators to acquire and maintain URLs for hospital and health system websites, it simplifies the work of associating one or more files to a hospital and spending time poking around on websites to actually find MRF data.
Joey Plater, Solutions Engineer
Data retrieval and standardization activities will require less time and technical resources. More time and differentiation will be allocated to transformational activities such as data enrichment, integration with SaaS tools, programmatic access/APIs, data quality, verification, and reconciliation with other sources (e.g., Transparency in Coverage payer data or claims).
Adam Geitgey, CTO
I expect better calibration of our scorecard model. In general, it’s easier to assess file quality when the entity that created the file understands the parameters and requirements the file will be evaluated on. The new schema format clearly defines what hospitals should post and how the data should be organized. As a result, monitoring and scoring thousands of MRFs should become more uniform and automated.
Did anything else in the Proposed Rule catch your eye?
Ryan Kim, Product Manager
I find myself asking, “What else does this unlock?” It’ll allow us to improve our speed in comparing payer data to hospital data because we won’t have to spend as much time parsing each unique hospital MRF.
The Proposed Rule also requires hospitals to include their drug pricing data in the new MRF. I’ve been working on a team building out a process to efficiently capture drug units and measurements. It feels like the future of drug pricing is here, and we’ve opened Pandora’s Box to dig into drug rates data quality and validation.
Paul Zuradzki, Data Engineer
I agree with Ryan! We will have more standardization on drug data. Interpreting drug units and quantities is often tricky, whether it be pricing data or claims. Units/quantities may or may be reported in "eaches" (price per each item) or based on some sort of measurement quantity of volume or mass (mL, grams, etc.). The service description says “10ML”, but the quantity and units field may indicate the price unit of measurement is something (per vial, package, other). Those variances are a major hindrance to understanding drug pricing.
Adam Geitgey, CTO
Not only has CMS laid out price competition, they’ve also paved the way for increased consumer choices. In my opinion, consumers should be able to choose based on price and certainty. The Proposed Rule requires hospitals to disclose an algorithm and a formula for payment when items or services do not have a negotiated fixed rate. This would give consumers a choice to a place with a certain dollar amount, even if the price might be higher, or in the case of the uncertain algorithmic estimate, even if the price might be lower.
Curious to learn more about the Proposed Rule? Check our MRF update page for additional details.