Hospital Compliance With Federal Price Transparency Requirements: Updated Review of Madison, Wisconsin Hospitals

In August 2021 I reviewed Madison hospitals’ compliance with the Federal “Hospital Price Transparency Final Rule,” which requires hospitals to make their make their standard charges readily available to the public, in both “consumer-friendly” and “machine-readable” formats. Hospitals have now had an additional five months to come into compliance, and it’s time for an update to see how local hospitals are doing.

The current review method is similar to the prior report, with searches on the websites of the three main hospitals in Madison (SSM Health St. Mary’s, UnityPoint Meriter, and UW Health University) for availability of both formats, particularly for the the six behavioral health services required to be reported among 300 “shoppable services,” (defined as “a service that can be scheduled by a health care consumer in advance”).

A checklist was designed for the site reviews based on CMS guidance (“10 Steps to Making Public Standard Charges for Shoppable Services,”) including six required criteria. Since the price of health services – particularly psychotherapy – is often hidden to consumers seeking care, when these prices were located through this review, prices are listed here for the six key behavioral health services: individual therapy in 30, 45, and 60 minute increments, family therapy with and without the “identified patient” present, and group therapy.

Results

None of the three hospitals were in full compliance with the transparency rule in August 2021 (See Table 1). None are in full compliance at this time. A few improvements are noted. Prices when available appear to be quite variable. Easy access by consumers to the cost of therapy at these three hospitals remains elusive. Gaps also continue in availability of quality measures related to therapy as well as financial assistance information in languages other than English that are likely to occur in local communities.


2022 SSM Health St. Mary’s Hospital – Madison

https://www.ssmhealth.com/locations/st-marys-hospital-madison

COMPLIANCE CHECKLIST

CRITERION 2022 2021 NOTES
Comprehensive machine-readable file Yes Yes json format
Consumer-friendly display of standard charges for at least 300 ‘shoppable’ services grouped with charges for ancillary services that are customarily provided by the hospital (see Alternative Checklist) Yes/No Yes Initial search straightforward by link from ‘Resources/Price Transparency’ menu on main page

Specific charges search shows no behavioral health grouping, no results with obvious search terms such as ‘therapy,’ ‘family therapy’, ‘group therapy.’ Consumer would have to know the technical medical procedure code.

Notification if financial aid, payment plans, and assistance in enrolling for Medicaid or a state program are available Yes No
Quality of care indicators if available No No
Displaying information in languages other than English to meet the needs of the communities and populations the hospital serves No No
Clear communication about location at which the shoppable service is provided if hospital has more than one location, and whether estimate is for an inpatient or outpatient service Yes/No No Search allowed by hospital within system

No clear indication of in- versus outpatient service for psychotherapy at hospitals where this is provided

Source:  10 Steps to Making Public Standard Charges for Shoppable Services

PRICES

Behavioral Health Service

Price (Uninsured Self-pay)

Psychotherapy with patient 30 minutes “This procedure is not provided by this hospital.”
Psychotherapy with patient 45 minutes

Same as above

Psychotherapy with patient 60 minutes

Same as above

Family psychotherapy without patient present 50 minutes

Same as above

Family psychotherapy with patient present 50 minutes

Same as above

Group psychotherapy

Same as above

 

NoteThough the “shoppable service” search reports these services are not provided at this hospital, these services are listed along with prices in the machine readable and pdf files available on the website.


2022 UnityPoint Health Meriter

https://www.unitypoint.org/madison/default.aspx

COMPLIANCE CHECKLIST

CRITERION

2022

2021

NOTES

Comprehensive machine-readable file

Yes

Yes At https://www.unitypoint.org/madison/patient-charges-and-costs.aspx in machine-readable and pdf formats
Consumer-friendly display of standard charges for at least 300 ‘shoppable’ services grouped with charges for ancillary services that are customarily provided by the hospital (see Alternative Checklist)

Yes shoppable

No ancillary

Yes shoppable

No ancillary

At https://www.unitypoint.org/madison/patient-charges-and-costs.aspx
Notification if financial aid, payment plans, and assistance in enrolling for Medicaid or a state program are available

Yes

Yes

At https://www.unitypoint.org/madison/patient-charges-and-costs.aspx and https://www.unitypoint.org/madison/financial-assistance.aspx
Quality of care indicators if available

No

No

Displaying information in languages other than English to meet the needs of the communities and populations the hospital serves

No

No

Clear communication about location at which the shoppable service is provided if hospital has more than one location, and whether estimate is for an inpatient or outpatient service

Yes Location

No in- versus outpatient

Yes Location

No in- versus outpatient

Source for checklist:  10 Steps to Making Public Standard Charges for Shoppable Services

PRICES

Behavioral Health Service

Price (Uninsured Self-pay)

Psychotherapy with patient 30  minutes ”We couldn’t create an estimate with the information you provided. Please call us at [number] for further assistance”
Psychotherapy with patient 45 minutes Same as above
Psychotherapy with patient 60 minutes Same as above
Family psychotherapy without patient present 50 minutes We didn’t find any services matching your search. Try searching for a different keyword or browsing the categories tab.”
Family psychotherapy with patient present 50 minutes Not listed and/or not provided at main hospital. Price at affiliated hospital in IL (UPH PEORIA METHODIST) shows “total hospital fee” of $519, with 20% discount and “you pay” price of $415
90853 Group psychotherapy No listing and/or not provided at main hospital. Prices at affiliated hospitals:

Peoria Full Fee $922 “You pay” $738

Waterloo IA Full fee  $1289 “You pay” $1031

Dubuque IA Full fee $1854 “You pay” $1854

Quad Cities “couldn’t create estimate”

Cedar Rapids Full fee $1098 “You pay” $878

Sioux City Full fee $3416 “You pay” $2733

Note: Though prices are not listed for main hospital in a “shoppable services” search, they are listed in both the machine-readable and pdf as well as searchable CDM at https://www.unitypoint.org/madison/patient-charges-and-costs.aspx. These files are not likely to be understandable to consumers.

Initial search suggests need to provide personally identifying information at https://www.unitypoint.org/madison/online-estimate.aspx

Non-identfiable search located at https://www.unitypoint.org/madison/patient-charges-and-costs.aspx and https://tinyl.io/5XI5

 


2022 University Hospital

https://www.uwhealth.org/locations/university-hospital-170

COMPLIANCE CHECKLIST

CRITERION 2022

 2021

NOTES
Comprehensive machine-readable file

Yes

Yes

In spreadsheet format
Consumer-friendly display of standard charges for at least 300 ‘shoppable’ services grouped with charges for ancillary services that are customarily provided by the hospital (see Alternative Checklist)

Yes

Yes

No obvious link from main page, requires search with ‘price transparency’ or related terms
Notification if financial aid, payment plans, and assistance in enrolling for Medicaid or a state program are available

Yes

No

Quality of care indicators if available

Yes/No

No

Categories and descriptions, no data/comparable measures apparent
Displaying information in languages other than English to meet the needs of the communities and populations the hospital serves

Yes/No

N

In Spanish, no other languages apparent
Clear communication about location at which the shoppable service is provided if hospital has more than one location, and whether estimate is for an inpatient or outpatient service

Yes/No

Y

Yes for location, no clear indication of in- versus outpatient pricing

Source for checklist:  10 Steps to Making Public Standard Charges for Shoppable Services

PRICES

Behavioral Health Service

Price (Uninsured Self-pay)

Psychotherapy with patient 30 minutes

$154* Full fee $237

Psychotherapy with patient 45 minutes

$239 Full fee $368

Psychotherapy with patient 60 minutes

$349 Full fee $537

Family psychotherapy without patient present 50 minutes

$246 Full fee $379

Family psychotherapy with patient present 50 minutes

$238 Full fee $366

Group psychotherapy

$92 Full fee $142

*All prices show “35% discount” from full fee to uninsured self-pay fee.


Discussion

Since the 2021 review, beginning January 1, 2022 the penalties for hospital noncompliance have been increased to $300 per day for hospitals with 30 or fewer beds, up to $5,500 maximum per day, and $10 per bed per day for hospitals with more than 30 beds (which applies to all three of these Madison hospitals), with a minimum total penalty of $109,500 per hospital, and maximum total penalty up to  $2,007,500 per hospital. CMS has issued warning letters to more than 300 hospitals, and, if penalized, hospitals may be publicly identified on the CMS website. No monetary penalties have yet been assessed, and it unclear whether any of the Madison hospitals have been warned. Given the results of this review, local hospitals may be at risk of being penalized. The public may submit complaints.

Considering the variability in prices when these are available, shopping for therapy services based at least in part on price may benefit consumers, particularly if there is flexibility on choice of location. Given that quality data for behavioral health services do not appear to be publicly reported at this time for the hospitals reviewed, shopping on price may be a key consideration for consumers. Questions of quality may still need to be done the “old fashioned way”: word of mouth, and asking trusted others where they may have had positive or less satisfactory experiences with clinicians.

 

Leave a Reply

Your email address will not be published. Required fields are marked *

5 × 4 =

This site uses Akismet to reduce spam. Learn how your comment data is processed.