Compliance of National Cancer Institute–Designated Cancer Centers With January 2021 Price Transparency Requirements

Abstract

This cross-sectional study investigates the compliance rate of hospitals with National Cancer Institute–designated cancer center status with the Centers for Medicare & Medicaid Services January 2021 price transparency requirements.

In an effort to increase competition and drive down prices, the Centers for Medicare & Medicaid Services (CMS) initiated 2 policies in the last 3 years to increase hospital price transparency.¹ Starting January 2019, hospitals were required to publish their chargemasters—a list of the nondiscounted prices for services provided. This effort has been criticized because charges rarely reflect the actual prices paid for a service and do little to spur competition.^2,3 In response to this criticism, CMS expanded this mandate in January 2021 to require hospitals to publish a list of their negotiated rates with health insurers. In theory, this should more effectively increase competition between payors and hospitals and drive down rates.

Care for patients with cancer is one of the largest segments of health care spending in the US, estimated at approximately $200 billion annually.⁴ We aimed to assess the compliance rate of hospitals with NCI-designated cancer center status with this updated mandate and the overall usefulness of the information provided.

Methods

In August 2021, the websites of all 63 hospitals with NCI-designated cancer center status were searched to assess whether or not they posted a list of negotiated rates. Among those that did, we assessed their compliance against 5 federal criteria (Table).¹ These criteria relate to both how the file was posted and the content of the file. We assessed how compliance rates varied based on type of NCI designation (comprehensive cancer center vs clinical cancer center) as well as by census region. Lastly, for hospitals that provided reimbursement information for specific diagnosis-related groups (DRGs), we extracted minimum and maximum payor rates and compared this within and across hospitals for 3 cancer operations: stomach/esophagus (DRG 328), colon (331), and pancreas (407). This analysis did not meet the definition of human participants research, and the STROBE reporting guidelines were followed.

Table. Key Criteria in the 2021 Centers for Medicare & Medicaid Services Price Transparency Requirement.

Criteria	Specific requirement
1	A file is posted in a machine-readable format (.json, .xml, .csv).
2	The file must be free of charge without requiring registration or personal identifying information.
3	The file must be named appropriately.
4	The file contains a list of all items and services for which the hospital charges.
5	For each item/service, the following 5 items must be available: 1. Gross charge (eg, charge master rate, no discount) 2. Payor-specific negotiated charge with the name of the payor 3. Deidentified minimum negotiated charge 4. Deidentified maximum negotiated charge 5. Discounted cash price (eg, for those without insurance)

Results

Of the 63 included hospitals, approximately two-thirds (42 of 63) provided some information on negotiated rates. However, fewer than one-third (20 of 63) were fully compliant with the current law. Compliance varied across criteria; the majority of violations were because hospitals did not (1) post the file in a machine-readable format (n = 12, criteria 1) or (2) provide all 5 price parameters (n = 10, criteria 5). Comprehensive cancer center–designated hospitals had higher compliance than those with clinical cancer center designation (74% vs 33%; P < .01), and those in the West were generally better than those in the South (86% vs 57%; P = .09). Few hospitals (range, 15-18) provided payor-specific DRG payments for gastrointestinal cancer operations. There was large variation in minimum and maximum payments for different payors both within and across hospitals across all 3 DRGs (Figure).

Figure. Minimum and Maximum Payment Variation for Common Gastrointestinal (GI) Surgeries.

A, Across-hospital and within-hospital (B) payment variation for common GI surgeries. Sample includes all hospitals (irrespective of number of compliance criteria met) that provided diagnosis-related group (DRG)–specific payment values. DRG 328 indicates stomach/esophagus; DRG 331, colon; DRG 407, pancreas.

Discussion

In this cross-sectional study, only one-third of hospitals with NCI cancer center designation were fully compliant with the current CMS price transparency mandate to publish negotiated rates with payors. What is less easy to convey in a quantitative fashion is how cumbersome most websites or files were to navigate. Many files were several gigabytes large and required advanced coding and statistical experience to open or analyze. Most files had tens of thousands of rows of information and no uniformity regarding services listed or insurer categorization. One hospital had the phrase “variable” listed over 100 000 times.

An optimistic view of the current analysis is that among the few hospitals that did provide adequate and well-annotated information, there was large variation in payments both within and across hospitals. If a well-executed mandate did spur competition, the large variation identified in this study could suggest significant cost savings.

The primary limitation of this analysis was the early evaluation of hospitals; compliance will likely increase over time as the federal government enforces the mandate. Although there does appear to be potential in providing payor-negotiated rate information, most hospitals with NCI designation are not fully compliant; among those that are, comparability and accessibility of data are major limitations.