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'Patients Over Profits:' How to Stay Ahead on Price Transparency Compliance

Analysis  |  By Amanda Norris  
   August 30, 2023

No recent regulation has thrown revenue cycle processes for a loop like the No Surprises Act.

CMS’ price transparency requirements, found within the No Surprises Act, have been implemented for years now, and it’s clear that not many recent regulations have caused such a shakeup in revenue cycle processes.

From streamlining technology to training staff, many revenue cycle leaders had to scramble to adhere to the law and remain out of CMS’ crosshairs.

While there are a few hospitals feeling the wrath of CMS for noncompliance, there are also hospitals and health systems immerging for excellence in adherence.

In fact, recently awarded 15 hospitals and health systems for what it says is exemplary transparency compliance, including in some cases a record of significant improvement, which the group says demonstrates a commitment to putting patients over profits.

Awarded by the group were the following hospitals and health systems:


  • Best-in-Class: Rush University Medical Center – Chicago, IL
  • Baton Rouge General - Mid City – Baton Rouge, LA
  • Grandview Medical Center – Birmingham, AL
  • Mercy Hospital Downtown Bakersfield – Bakersfield, CA
  • MetroHealth Medical Center – Cleveland, OH
  • Pullman Regional Hospital – Pullman, WA
  • Ridgeview Medical Center – Waconia, MN
  • Robert Wood Johnson University Hospital New Brunswick – New Brunswick, NJ
  • Saint Tammany Parish Hospital – Covington, LA
  • UW Health University Hospital – Madison, WI

Hospital Systems

  • Kaiser Permanente – Oakland, CA (98% compliance)
  • Community Health Systems – Franklin, TN (97% compliance)
  • Universal Health Services – King of Prussia, PA (92% compliance)
  • CommonSpirit Health – Chicago, IL (88% compliance)
  • LifePoint Health – Brentwood, TN (83% compliance)

For those hospitals and health systems that are still working to streamline compliance, there are lessons to be learned from those systems that are coming out ahead.

For example, Tina Barsallo, vice president of revenue cycle operations at Lifepoint Health, spoke to HealthLeaders about the health systems’ strategies in compliance.

To really get ahead of the game, Barsallo said Lifepoint created an internal pricing transparency team in the year prior to the regulation’s effective date.

Team members spanned across the entire organization and included revenue cycle operations, revenue cycle analytics, compliance, managed care, legal, and project management. Barsallo says she even brought in other team members as needed, such as the facility revenue cycle management leaders and CFOs.

Its pricing transparency team evaluated the requirements thoroughly and outlined the proper path for Lifepoint, and then executed on each aspect to ensure the requirements were met. Barsallo says the team continues to meet regularly to confirm there have been no changes to the requirements, and the revenue cycle team handles on-going monitoring of the websites and links, as well as the annual refresh.

Even if you’re already behind on compliance, it’s not too late to make a change. Barsallo suggests that revenue cycle leaders pull a team together to create joint ownership and partnership in creation of any price transparency tools and to help drive consistency and compliance.

“Reach out to peers to brainstorm on ways they have accomplished compliance, so you don’t need to reinvent the wheel. It is extremely helpful to collaborate with other providers and health systems,” Barsallo says.

Amanda Norris is the Director of Content for HealthLeaders.


From streamlining technology to training staff, many revenue cycle leaders had to scramble to adhere to the law and remain out of CMS' crosshairs.

Even if you're already behind on compliance, it's not too late to make a change.

The VP of revenue cycle operations at Lifepoint Health, a system recently awarded for price transparency excellence, shares her strategies for staying ahead on compliance. 

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