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“Hospital Price Transparency – Compliance and Business Implications” – John Harris, Managing Director

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John Harris, Managing Director of Veralon, and Chris Raphaely of Cozen O’Connor

Shifting the $1 trillion dollar hospital industry from confidential payer contracts to publicly published pricing is a massive transformation. New CMS hospital price transparency requirement implicate public relations and business strategy issues, yielding a wide range of hospital and health system approaches to reporting the required data. As compliance increases, we are entering a world of publicly visible payer contracts which affect everything from negotiation strategies to value-based care. We will review: the specific regulatory requirements to report hospital pricing data, the risk of partial compliance, CMS penalties and the implication of pricing transparency on confidentiality clauses in payer contracts; a sample of Philadelphia area pricing data; and what this change means for payer negotiations, value based care, pricing strategy and other business issues.