Presentation by David Kelly, MHSA, FHFMA, CRCR, Director, Operations Excellence, Piedmont Healthcare - marcus evans National Healthcare CXO Summit Oct 16-18, 2022-Boston MA

1. No Surprises Act and Price
Transparency:
Going Beyond Compliance to Build Patient Trust and Protect Your Brand
David Kelly, MHSA, FHFMA

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Table of Contents
• Disclaimer
• Regulatory Background
• Social/Media Background
• What do Patients Actually Want?
• Moving past Compliance
• Q&A
• Speaker Bio
• Sources

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Introduction

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Audience Survey
By show of hands, what % of US Hospitals do you believe is FULLY
compliant with the letter of the law in terms of Federal Price
Transparency rules?
• 10%
• 25%
• 50%
• 75%
• >90%
True answer is probably “it depends”
– definitions are still being
challenged, and technical
omissions could find you in
trouble1

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Disclaimer
I am not a lawyer and this presentation should not be construed as legal or
compliance advice. If you have specific legal or rules questions based on todays
presentations, consult with your counsel and compliance departments.

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Background

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Regulatory Background
In addition to federal laws and rules that we’ll discuss today,
many states have their own laws, rules, and regulations.
Compliancy2 varies widely – in part due to definitions of
transparency – something we’ll come back to later.

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No Surprises Act
Numerous rules have been published regarding the No Surprises
Act. CMS has a solid site3 available to help you navigate. Key
highlights:
• Balance Billing protections
• Requirement to inform about cost sharing
• Arbitration guidelines for patient-provider and
payer-provider disputes

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Price Transparency
• Must be in a specific format and
posted online
• Has key elements that must be
included
Machine Readable
File
• At least 300 “shoppable services”
• Key elements must be included
Consumer-Friendly
Display of
Shoppable Services

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Social / Media Background

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Providers are Constantly in the News…

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Patients First?

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What Do Patients Actually Want?
4
5

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Do Consumers Even Price Shop Healthcare?
Data seems conflicted on this.
• Released in early October6, data shows only ~1/3 Americans
has ever priced shopped for healthcare
• However, Data from 20207 shows 91% of people surveyed
would price shop
An anecdote from the ultimate price shopping community:

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Is This All Even Worth It?
Do broad patient populations make decisions primarily on cost?
Some studies8,9 say NO.
In the 1990’s, the Danish health system mandated transparency and saw
prices go UP!10
This Brings
Us to a
Choice

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Moving Past Compliance

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Who / What are you Solving for?
OR

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Solving for Regulation (Compliance)
This becomes a risk, reserves, and public image question
Legal / Risk Compliance
Analyze
Exposure
The letter of the
law matters
Ongoing
discussions and
assessment
Marketing
Media and
Regulator
Feedback
Press
Release(s)
Social Media
Stance
Finance
Financial
Reserves
Refund policies
Staff
Scripting
Training
Support!

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Audience Survey – Digital Front Door
By show of hands, how many of you have implemented, are
implementing, or are evaluating a “digital front door” initiative in
your organization?
8 Key Components of
a Digital Front Door -
iPro Healthcare (ipro-
inc.com)
Some Hospitals are
Opening a ‘Digital
Front Door’ | Deloitte
US
Digital Front Door
Solutions & Patient
Experience | Orion
Health
Creating a digital front
door to the hospital
(philips.com)
A Digital Front Door
Strategy: What It Is,
Isn't, and Why You
Need One - Relatient
5 Sources – Only 1 talks Estimation & Costs

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Solving for Patients
If you want to go beyond compliance, first things first:
1) Don’t confuse your Digital Front
Door with meeting patient price
transparency efforts.
Their Venn overlaps a lot, but it
isn’t the same.
1) Make this a priority. Disruptors
are moving into this space, media
and regulators are pushing, and
patient expectations are high.

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Some Tactics
Figure out what YOUR patients in YOUR markets want
Regulatory
• Nuance to your
approach
• e.g. Minimal
transparency
files but heavy
on Estimation
Outcomes-
Focus
• Price
Guarantees
• NSA essentially
dictates this
already for Self
Pay
Changing
Dynamics
with
Providers
• Universal Billing
• “All inclusive”
approach
Marketing
and Media
• Scripting and
Patient
Experience
stance must be
adjusted to
match

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Educate, Educate, Educate
Offer Financial Counseling
 Not just for inpatients
 Credit and long-term payment
options
 The return of layaway
 Counseling for patients’ bills
beyond your own?
Staff Education
 Do ALL your team members
understand your financial
approach?
 Do they get WHY this matters?
 Impacts of Finances on Patients
are bigger than ever, and
impact care11
Patients
Providers
Nurses
Caregivers/Clinical
Staff
Family
Support Staff

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Questions?
This Photo by Unknown Author is licensed under CC BY-SA-NC

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Bio / Credentials
David has been in healthcare for over 16 years with
12+ of those in revenue cycle. He’s worked for
both small community hospitals and large ($10+ bn
health systems) as well as healthcare consulting
firms and life sciences organization. He received
his Masters in Health Services Administration in
2010, is a Fellow of the Healthcare Financial
Management Association (FHFMA) and a Certified
Revenue Cycle Representative.
He is an expert in patient-facing financial
interactions and has led efforts across his
background to reduce patient friction within the
admitting and registration process.
He resides in Ohio and works for Piedmont
Healthcare, Georgia’s largest non-profit health
system and supports their Patient Financial Care
division as a Director of Operations Effectiveness.

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Sources
1 - Hospitals still aren't complying with transparency rules (axios.com)
2 - Hospital Price Transparency Compliance by State: 3 Takeaways (hcpricing.com)
3 - Overview of rules & fact sheets | CMS
4 - Americans planning to save, not splurge with tax refunds this year - iXtenso – retail trends
5 - Here's what Americans plan to spend more money on as inflation rises (cnbc.com)
6 - Survey Finds Majority of Healthcare Consumers Conditioned to Not Shop Around for the Best
Price (prnewswire.com)
7 - Americans Want Healthcare Price Transparency (lugpa.org)
8 - Association Between Availability of a Price Transparency Tool and Outpatient Spending | Health
Care Economics, Insurance, Payment | JAMA | JAMA Network
9 - Use patterns of a state health care price transparency web site: what do patients shop for? -
PubMed (nih.gov)
10 - Government‐Assisted Oligopoly Coordination? A Concrete Case - Albæk - 1997 - The Journal of
Industrial Economics - Wiley Online Library
11 - How does cost affect access to care? - Peterson-KFF Health System Tracker

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Thank you