We focused our feedback on section XVIII of the act, “Proposed Updates to Requirements for Hospitals to Make Public a List of Their Standard Charges.”
Turquoise is in full support of CMS’ commitment to continued improvement and iteration of Hospital Price Transparency requirements. While Turquoise has observed a significant uptick in MRF disclosures from 2021 to 2023, the MRFs are still plagued by schema inconsistencies and missing contents that are hard to police with automation. These shortcomings also limit the utility of existing macroeconomic and microeconomic applications.
The proposed requirement to mandate a standardized schema for hospital MRFs is critical and urgent to address the issues with data utility. We are in agreement with this update.
Our full comment can be summarized as follows:
- We iterate our strong support as a leading third-party innovator in the industry for all of the newly proposed disclosure requirements
- We ask for clarification around two finer details of the newly required hospital MRF schema
- We close with thematic suggestions for continued regulatory iteration on behalf of consumers, either through the Final Rule or in subsequent rulemaking