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  1. FHIR Specification Feedback
  2. FHIR-40361

Display element for coded content is required to comply with Transparency Rule

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    • Icon: Change Request Change Request
    • Resolution: Persuasive with Modification
    • Icon: Medium Medium
    • US CARIN Blue Button (FHIR)
    • current
    • Financial Mgmt
    • General Guidance
      Terminology Licensure
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      To the "Considerations for Improving Interoperability" section, after the first paragraph, add the following language:

      Payers should note that some authors of proprietary code systems used in this Implementation Guide allow for expression of code descriptions depending on use. Some of these code systems may go further and provide consumer-friendly descriptors of these codes, such as the American Medical Association(c) CPT(R) which provides a "Consumer Friendly Descriptor" for its codes. Payers should strongly consider including these descriptors to make the information they provide to their members more usable for them.

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      To the " Considerations for Improving Interoperability " section, after the first paragraph, add the following language: Payers should note that some authors of proprietary code systems used in this Implementation Guide allow for expression of code descriptions depending on use. Some of these code systems may go further and provide consumer-friendly descriptors of these codes, such as the American Medical Association(c) CPT(R) which provides a " Consumer Friendly Descriptor " for its codes. Payers should strongly consider including these descriptors to make the information they provide to their members more usable for them.
    • Clarification

    Description

      In this article, AMA encourages providers and payers to use patient friendly descriptors.
      https://www.ama-assn.org/delivering-care/patient-support-advocacy/cpt-descriptors-comply-transparency-rule-health-plans-and
       
      Requiring information sources to populate the display element of a coded concept would ACTUALLY make it possible to provide "the information" to the patient. Patient access apps would FINALLY be able to render this information that is provided by Payors and Providers.  Without including the patient friendly display, providing only codes that patients don't understand is just a new form of information blocking.  
       
      The constraints on the display element for any coded concept needs to be tightened to a SHOULD–if not a SHALL–depending on how serious the IG is about complying with the Transparency Rule for health plans and hospitals.
       
      The clear guidance from this article should be highlighted in the General Guidance Section and covered in more detail in the Terminology Licensing section of the IG.
       
      The AMA writes,"For Health Plans, the Final Rule on Price Transparency (CMS-1717-F2) goes into effect on July 1, 2022. Are you prepared to be compliant? According to the requirements, health plans and hospitals must publicly disclose a list of their standard charges for the items and services they provide as well as a list of shoppable services in a searchable and machine-readable format. The AMA is supportive of the final rule and its goals of better price transparency and public access to health plan and hospital standard charges.

      In addition to the Current Procedural Terminology (CPT®) codes, health plans and hospitals may use CPT consumer-friendly descriptors to comply with the requirement of the final rule for a plain language description of services. These descriptions are already included in the CPT license for every code."

      HL7 should have this clear expectation clearly spelled out for all proprietary code systems that seek to be suggested for use in an HL7 Implementation Guide.  As a minimum they should be required by HL7 to sign a pledge to support patient access and transparency, and agree to this simple necessity to prevent information from being blocked from patients.

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            LisaRNelson Lisa R. Nelson
            Lisa R. Nelson
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