Resource Library: Results | Outpatient Facility Fee Reform: A 50-State Review

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Commercial Price Variation for Common Cardiovascular Services Across 4 Major US Insurers

Authors: Alexander P Philips, Sanket S Dhruva, and Christopher Whaley
Date: 7/1/2026
Resource Type: Peer-reviewed article
The study finds substantial variation in negotiated cardiology service prices across commercial insurers, with greater variation in facility fees than professional fees.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance
Summary: Using April 2025 Transparency in Coverage data, the researchers examine how negotiated allowed amounts for common cardiology services vary across four major commercial insurers. They find greater variation in facility fees than in professional fees for cardiology services, as well as significant differences in negotiated facility prices across payers. The researchers also find substantial variation in median professional and facility fee rates across states for coronary angiography.
Funding Disclosure: Arnold Ventures, the Robert Wood Johnson Foundation, PatientRightsAdvocates.org, and the National Institute for Health Care Management Foundation provided funding for this work.
Topic Areas: Payment Differentials, Vertical Integration, Facility Fees
Citation: Philips AP, Dhruva SS, Whaley C. Commercial Price Variation for Common Cardiovascular Services Across 4 Major US Insurers. JAMA Netw Open. 2026;9;(7):e2623326. doi:10.1001/jamanetworkopen.2026.23326.

Estimated Impact of a Facility Fee Ban for Routine Services in Illinois

Authors: Center for Advancing Health Policy through Research
Date: 7/1/2026
Resource Type: Gray literature
The brief finds that a facility fee prohibition on evaluation and management services and preventive services across 149 hospitals in Illinois would save approximately $348.3 million per year in the commercial market.
Details
Publisher/Organization: Center for Advancing Health Policy through Research
Payer: Commercial Insurance
Summary: Using 2023 Transparency in Coverage data and 2024 National Academy for State Health Policy Hospital Cost Tool data, the researchers estimate that a facility fee prohibition on evaluation and management services and preventive services would save approximately $348.3 million annually in the commercial insurance market across 149 hospitals in Illinois. After the ban, commercial operating margins at these hospitals would be expected to average 34.4% (down from 35.4%) and overall operating margins are expected to average 11.0% (down from 11.5%). The researchers suggest this facility fee ban could result in substantial health care savings while having a minor impact on the operating profit margins of the affected hospitals.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Facility Fees, Policy Reforms
Citation: Center for Advancing Health Policy through Research. Estimated Impact of a Facility Fee Ban for Routine Services in Illinois. Center for Advancing Health Policy through Research, Brown University School of Public Health; July 2026. https://doi.org/10.26300/r3a4-kh48.

Effects of Vertical Integration on Providers’ Billing and Practice Patterns in ESI (2018-2022)

Authors: Jessica Chang, Caroline Picher, Marissa Myers, and Raphael Gaeta
Date: 4/1/2026
Resource Type: Gray literature
The report shows that from 2018 to 2022, health system acquisitions of independent practices were associated with higher-intensity billing and greater use of hospital-based diagnostic tests but not increased facility fee billing.
Details
Publisher/Organization: Health Care Cost Institute
Payer: Commercial Insurance
Summary: Using commercial claims data for individuals with employer-sponsored insurance from 2018 to 2022, the researchers analyzed changes in clinician billing patterns following a health system's acquisition of an independent practice. They found that clinicians billed for higher-intensity evaluation and management visits and were more likely to order hospital-based diagnostic tests after the acquisition. However, the likelihood of billing a facility fee with an office visit did not increase following the acquisition.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Vertical Integration, Facility Fees
Citation: Chang J, Picher C, Myers M, Gaeta R. Effects of Vertical Integration on Providers’ Billing and Practice Patterns in ESI (2018-2022). Health Care Cost Institute; April 23, 2026. https://healthcostinstitute.org/all-hcci-reports/effects-of-vertical-integration-on-providers-billing-and-practice-patterns-in-esi-2018-2022/.

Site-Neutral Payment Reform and the Commercial Market

Authors: Christine H Monahan, Karen Davenport, Julia Burleson, and Kennah Watts
Date: 4/1/2026
Resource Type: Web content
The resource outlines a policy framework for implementing site-neutral payments in the commercial market to help policymakers develop reforms that fit their local situation.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Commercial Insurance
Summary: The resource highlights that the same services are often more expensive in hospital outpatient departments (HOPDs) than independent provider offices. Outpatient facility fees and rising hospital prices driven by the increasing market power of consolidated health systems contribute to higher payments for HOPDs. To address this, the resource covers 16 decision points across four domains to help policymakers develop a policy solution that best fits their local needs, circumstances, and priorities.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Vertical Integration, Payment Differentials, Policy Reforms, Site-Neutrality, Facility Fees
Citation: Monahan CH, Davenport K, Burleson J, et al. Site-Neutral Payment Reform and the Commercial Market. Georgetown University Center on Health Insurance Reforms; April 2026. https://chir.georgetown.edu/site-neutral-payment

The Hospital Cost Crisis: How Government Policies Drive Consolidation, Undermine Competition, and Fuel Soaring Prices

Authors: John R Graham
Date: 4/1/2026
Resource Type: Gray literature
The paper finds that site-of-service differentials contribute to integration between hospitals and independent practices and recommends site-neutral payment reform for public payers.
Details
Publisher/Organization: Paragon Health Institute
Payer: Medicare, Medicaid
Summary: This paper argues that site-of-service payment differentials between hospital outpatient departments and lower-cost settings have encouraged hospitals to acquire physician practices. According to the paper, these acquisitions have contributed to rising hospital costs. To promote competition and reduce unnecessary spending, the paper recommends site-neutral payment reform for Medicare and Medicaid.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Facility Fees, Vertical Integration, Site-Neutrality, Policy Reforms
Citation: Graham JR. The Hospital Cost Crisis: How Government Policies Drive Consolidation, Undermine Competition, and Fuel Soaring Prices. Paragon Health Institute; April 22, 2026. https://paragoninstitute.org/private-health/the-hospital-cost-crisis-how-government-policies-drive-consolidation-undermine-competition-and-fuel-soaring-prices.

Unique National Provider Identifiers and a Push for Transparency

Authors: Christine H Monahan
Date: 3/1/2026
Resource Type: Gray literature
The article explains that requiring unique National Provider Identifiers for off-campus hospital outpatient departments could improve transparency and support site-neutral payment reform, but additional action is needed to maximize its impact.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Medicare
Summary: The article examines a 2026 federal law requiring hospitals to use unique National Provider Identifiers (NPIs) for each off-campus hospital outpatient department paid under Medicare. Current billing practices often obscure site of care, limiting the ability of state and federal regulators to enforce facility fee restrictions or implement site-neutral payment policies. The law aims to increase the accuracy of outpatient claims data and transparency on where care is delivered. The authors argue that additional action—such as requiring use of unique NPIs across all payers and improving data systems linking provider locations to parent organizations—would increase the impact of the new policy to the commercial market.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Policy Reforms, Facility Fees, Billing Transparency
Citation: Monahan CH. Unique National Provider Identifiers And A Push For Transparency. Health Affairs Forefront; March 25, 2026. doi:10.1377/forefront.20260324.115604

Assessing the Landscape of Hospital Outpatient Department Care

Authors: Chris Frenier
Date: 2/1/2026
Resource Type: Web content
The analysis of commercial claims data shows hospital outpatient departments are a major and growing driver of spending, largely due to facility fees and higher-cost procedures despite most visits being for lower-cost services.
Details
Publisher/Organization: Health Care Cost Institute
Payer: Commercial Insurance
Summary: Using commercial claims data for over 55 million individuals with employer-sponsored insurance from 2018 to 2022, researchers analyze trends in hospital outpatient department use and spending. They found that outpatient facility spending grew by 18% over the period. Facility fees accounted for 86.3% of outpatient spending per enrollee. While more than 75% of visits were for lower-cost services such as lab tests, imaging, and evaluation and management, a small share of high-cost procedures—particularly major surgeries—drove a disproportionate share of spending, accounting for 22.4% of total spending despite representing only 3% of visits.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Facility Fees
Citation: Frenier C. Assessing the Landscape of Hospital Outpatient Department Care. Health Care Cost Institute; February 17, 2026. https://healthcostinstitute.org/all-hcci-reports/assessing-the-landscape-of-hospital-outpatient-department-care/.

Most Office Visit Facility Fee Spending Is on Internal Medicine

Authors: Bianca Silva Gordon and Katie Martin
Date: 2/1/2026
Resource Type: Web content
The analysis finds that the prevalence of facility fee billing for evaluation and management visits in the commercial market is relatively low but can still generate significant spending.
Details
Publisher/Organization: Health Care Cost Institute
Payer: Commercial Insurance
Summary: This analysis examines facility fee billing for evaluation and management (E/M) visits in the commercial market. In 2022, 1.24% of E/M visits in the United States included a facility fee, with variation across states ranging from 0.25% to 5.38%. Despite relatively low prevalence of facility fees for E/M visits, the high volume of these services means facility fees still contribute meaningfully to overall spending. For example, a small decrease in the percentage of E/M visit facility fees from 2018 to 2022 reduced total facility fee spending by about $121 million. The number of facility fees for E/M visits varied by specialty, while total spending was concentrated in high-volume fields such as primary care and internal medicine.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Facility Fees
Citation: Gordon BS, Martin K. Most Office Visit Facility Fee Spending is on Internal Medicine. Health Care Cost Institute; February 6, 2026. https://healthcostinstitute.org/all-hcci-reports/most-office-visit-facility-fee-spending-is-on-internal-medicine/

Strategic Selection and Pricing Power: Optum’s Acquisitions of Ambulatory Surgery Centers and Physician Practices

Authors: Derek T Lake, Lawrence P Casalino, Michael R Richards, Sean Nicholson, Rahul Fernandez, Manyao Zhang, and Robert Tyler Braun
Date: 2/1/2026
Resource Type: Peer-reviewed article
The study analyzes Medicare and commercial claims finding that Optum’s vertical integration did not shift care to lower-cost ambulatory surgery centers but increased commercial prices at acquired facilities by 11%.
Details
Publisher/Organization: N/A
Payer: Medicare, Commercial Insurance
Summary: Using 2013-2021 Medicare claims and 2015-2018 commercial claims, the study evaluates Optum’s acquisition of physician practices and ambulatory surgery centers (ASCs). It finds no meaningful change in referrals from hospital outpatient departments to ASCs in Medicare after acquisitions. Instead, Optum acquired practices that already had high ASC use, consistent with strategic selection. In commercial markets, prices at acquired ASCs rose by 11%, driven by higher facility fees and increased professional fees for Optum-employed physicians.
Funding Disclosure: Arnold Ventures provided funding for this work.
Topic Areas: Facility Fees, Vertical Integration, Payment Differentials
Citation: Lake DT, Casalino L, Richards MR, Nicholson S, et al. Strategic Selection and Pricing Power: Optum’s Acquisitions of Ambulatory Surgery Centers and Physician Practices. Health Affairs; February 1, 2026. doi:10.1377/hlthaff.2025.01062.

Outpatient Outrage 2026: Hospital Prices for Care Outside of Hospitals

Authors: Noah Austin, Manasvi Reddy, and Patricia Kelmar
Date: 1/1/2026
Resource Type: Gray literature
The report documents how facility fees for outpatient care in the commercial market have become increasingly prevalent as hospitals acquire physician practices, raising costs with few patient benefits.
Details
Publisher/Organization: U.S. Public Interest Research Group
Payer: Commercial Insurance
Summary: This report analyzes the growing use of facility fees for hospital outpatient care in the commercial market. It shows that they are applied in settings without hospital-specific resources and can substantially increase charges for preventive care, diagnostic tests, and routine visits without improving quality. These fees raise out-of-pocket costs and insurance premiums. The report highlights how integration has increased physician employment by hospitals, making it harder for patients to avoid settings with facility fees. The report also reviews state legislative actions and proposes policies such as site-neutral payments, unique National Provider Identifiers, facility fee bans for routine outpatient services, and public reporting of facility fee charges and payments.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Facility Fees, Site-Neutrality, Vertical Integration, Policy Reforms, Billing Transparency
Citation: Austin N, Reddy M, Kelmar P. Outpatient Outrage 2026: Hospital Prices for Care Outside Hospitals. U.S. PIRG Education Fund; January 29, 2026. https://publicinterestnetwork.org/wp-content/uploads/2026/01/USPIRG-Outpatient-Outrage-2026-Report-Jan-29-2026.pdf.

From Check-Ups to Cha-Ching: Consumers’ Exposure to Facility Fees

Authors: Karen Davenport and Kennah Watts
Date: 12/1/2025
Resource Type: Web content
The blog shows how facility fees add unexpected costs to routine care, exposing consumers with commercial insurance to higher out-of-pocket costs.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Commercial Insurance
Summary: The blog explains how facility fees result in unexpected out-of-pocket costs for consumers with commercial insurance receiving routine care, including checkups, lab tests, and outpatient visits. High deductibles and complex benefit designs leave many patients particularly exposed to these fees. The researchers highlight that hospital acquisitions of physician practices and payment differences between hospital and non-hospital settings contribute to the growth of facility fees and higher overall costs. The blog also discusses state policy responses aiming to limit patient cost-sharing, prohibit certain facility fees, and improve transparency to help consumers better understand and compare prices.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Facility Fees, Payment Differentials, Policy Reforms
Citation: Davenport K, Watts K. From Check-Ups to Cha-Ching: Consumers’ Exposure to Facility Fees. Georgetown University Center on Health Insurance Reforms; December 15, 2025. https://chir.georgetown.edu/from-check-ups-to-cha-ching-consumers-exposure-to-facility-fees/

Hospital Finances Following Connecticut's Ban on Outpatient Facility Fees

Authors: Robert Tyler Braun, Rahul Joseph Fernandez, Rachel Swindle, Christine H Monahan, Dunc Williams
Date: 12/1/2025
Resource Type: Peer-reviewed article
The study finds that Connecticut’s ban on certain outpatient facility fees for commercial plans was associated with a decline in outpatient-to-total charges, with no significant change in operating margins.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Commercial Insurance
Summary: Using Hospital Medicare Cost Reports and National Academy for State Health Policy Hospital Cost Data from 2011-2022, researchers assess the financial impact of Connecticut’s ban on certain outpatient facility fees for commercial plans. Researchers do not find evidence that the facility fee ban impacted hospital operating margins. However, the findings suggest the hospitals’ outpatient charges had a relative decrease of 6.91% as a portion of total charges.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Facility Fees, Policy Reforms
Citation: Braun RT, Fernandez RJ, Swindle R, Monahan CH, Williams D. Hospital finances following Connecticut's ban on outpatient facility fees. Health Aff Sch. 2025;3(12):qxaf237. Published 2025 Dec 11. doi:10.1093/haschl/qxaf237

State Efforts to Monitor Outpatient Facility Fees

Authors: Julia Burleson, Karen Davenport, Rachel Swindle, and Christine H Monahan
Date: 10/1/2025
Resource Type: Gray literature
The article describes how Colorado, Maine, Connecticut, and Washington use claims and reporting data to monitor and analyze hospital outpatient facility fees in the commercial market and inform policy responses.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Commercial Insurance
Summary: The authors review state efforts to collect and analyze outpatient facility fee data. Facility fees often make care delivered in hospital settings more expensive than in physician offices, but limitations in claims data can obscure where and how hospitals bill these fees. Colorado, Maine, Connecticut, and Washington have implemented data reporting requirements to better identify facility fee billing patterns and trends. These efforts reveal rising facility fee charges and highlight challenges such as inconsistent data across claims. Monitoring provides insight into site-of-care price differences and informs potential policy responses to improve affordability.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Payment Differentials, Facility Fees, Policy Reforms
Citation: Burleson J, Davenport K, Swindle R, Monahan CH. State Efforts to Monitor Outpatient Facility Fees. Health Aff Forefront; October 6, 2025. doi:10.1377/forefront.20251002.95640

Reining in Hospital Prices

Authors: United States of Care and Brown University Center for Advancing Health Policy through Research
Date: 7/1/2025
Resource Type: Gray literature
The report evaluates site-neutral payments, facility fee bans, and hospital price caps, finding that each could generate substantial savings while maintaining positive hospital margins in Indiana, Massachusetts, and North Carolina.
Details
Publisher/Organization: US of Care
Payer: Commercial Insurance
Summary: This report analyzes how three payment policies—site-neutral payments, facility fee prohibitions, and commercial hospital price caps—could affect consumer costs and hospital finances in Indiana, Massachusetts, and North Carolina in 2022. The authors find that setting commercial site-neutral rates at 100% of the Medicare non-hospital payment rate for the 57 services MedPAC identified could reduce consumer premiums and out-of-pocket costs by over $840 million. Hospital operating margins in the states would also remain positive after the site-neutral reform. They also find that banning facility fees for evaluation and management, preventive, and telehealth services in hospital outpatient departments could save consumers $121-$323 million per state, while hospitals would continue to maintain positive operating margins. Finally, the report estimates that capping commercial hospital prices at 200% of Medicare rates could save over $5 billion per state without leading to negative hospital operating margins. The authors conclude that policies aimed at curbing excessive hospital payments could lower costs without threatening hospital financial viability.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Payment Differentials, Site-Neutrality, Policy Reforms, Facility Fees
Citation: United States of Care and Brown University Center for Advancing Health Policy through Research. Reining in Hospital Prices: Modeling Reforms in Indiana, Massachusetts, and North Carolina. United States of Care; July 23, 2025. https://unitedstatesofcare.org/usofcare-westhealth-hospitalprices-july2025/.

Facility Fees: What Are They and How Do They Impact Health Care Prices?

Authors: Bianca Silva Gordon and Katie Martin
Date: 5/1/2025
Resource Type: Web content
The issue brief illustrates how facility fees for routine visits at hospital outpatient departments increase the total cost of care compared to office-based settings among people with commercial insurance.
Details
Publisher/Organization: Health Care Cost Institute
Payer: Commercial Insurance
Summary: This issue brief explains what facility fees are and uses visual examples to compare the cost components of a primary care office visit and a pediatric wellness visit in 2022 across care settings for patients with commercial insurance. It shows that when these services are delivered in hospital outpatient departments, facility fees make up roughly half of the total cost, significantly increasing overall prices compared to physician offices. While the professional fee in hospital settings may be slightly lower than in an office—for example, $13 less for a primary care visit—the addition of a $114 facility fee results in a higher total cost. The analysis highlights how site-of-care billing practices and facility fees drive payment differentials and increase spending for routine outpatient services.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Payment Differentials, Facility Fees
Citation: Silva B, Martin K. Facility Fees: What are they and how do they impact health care prices?. Health Care Cost Institute; May 6, 2025. https://healthcostinstitute.org/all-hcci-reports/facility-fees-what-are-they-and-how-do-they-impact-health-care-prices/

Annual Report on Health Care Facility Fees

Authors: Maine Health Data Organization
Date: 1/1/2025
Resource Type: Data
This dataset of commercial claims in Maine reports median payments, number of episodes, and the share of total payment attributed to institutional and professional claims by CPT code, care setting, and payer.
Details
Publisher/Organization: Maine Health Data Organization
Payer: Commercial Insurance
Summary: This dataset from the Maine Health Data Organization uses commercial claims from Maine’s All-Payer Claims Database and represents about 73% of commercially insured individuals in the state. It includes facility and professional payments for 109 outpatient procedures across 197 healthcare settings from July 2023 to June 2024. The dataset contains claims from 16 commercial payers, including detailed breakouts for the five largest insurers, and organizes services into categories. For each CPT code, care setting, and payer, it reports median payments, the number of episodes, and the share of total payments attributable to institutional versus professional claims. It also includes a “split billing” analysis that identifies instances where both institutional and professional claims were submitted for the same service, enabling comparisons of how payments are distributed across settings and claim types.
Funding Disclosure: N/A
Topic Areas: Payment Differentials, Facility Fees
Citation: Maine Health Data Organization. Health Care Facility Fees – Facility Fee Payments. Maine Health Data Organization. https://mhdo.maine.gov/facilityFeePayments.htm

Connecticut: Facility Fees Filing

Authors: Connecticut Office of Health Strategy
Date: 2025 (annual)
Resource Type: Data
Presentations and annual reports with facility fee trends for on- and off-campus hospital outpatient departments for commercial payers, Medicare, and Medicaid.
Details
Publisher/Organization: Connecticut Office of Health Strategy
Payer: Commercial Insurance, Medicare, Medicaid
Summary: Since 2015, Connecticut has required hospitals and health systems to report detailed outpatient facility fee data from commercial payers, Medicare, and Medicaid. The data include total charges, the number of visits with facility fees by payer, and charges for the top ten procedures by revenue and utilization. The Connecticut Office of Health Strategy annually publishes reports summarizing this data. They show annual and multi-year facility fee trends for on- and off-campus hospital outpatient departments.
Funding Disclosure: N/A
Topic Areas: Facility Fees
Citation: Connecticut Office of Health Strategy. Facility Fees Filing. Connecticut OHS. https://portal.ct.gov/ohs/programs‑and‑initiatives/hospital‑data‑reporting/facility‑fees‑filing

Facility Fee Reporting

Authors: Washington State Department of Health
Date: 2025 (annual)
Resource Type: Data
Annual Washington state reports include facility fee data at off-campus hospital clinics including visit volume, revenue, and ranges of allowable payments from public or private payers.
Details
Publisher/Organization: Washington State Department of Health
Payer: Commercial Insurance, Medicare, Medicaid
Summary: Hospitals annually report data to Washington State on hospital facility fees charged at off-campus, provider-based clinics, including the number of such clinics that bill facility fees, total patient visits where facility fees were charged or billed, and total revenue generated from these fees. The reporting also includes the range of allowable facility fee payments received from public or private payers.
Funding Disclosure: N/A
Topic Areas: Facility Fees
Citation: Washington State Department of Health. Facility Fee Reporting: Hospital Facility Fees. Washington State Department of Health. https://doh.wa.gov/data‑statistical‑reports/healthcare‑washington/hospital‑and‑patient‑data/hospital‑financial‑data/hospital‑facility‑fees

Prices Paid to Hospitals by Private Health Plans: Findings from Round 5.1 of an Employer-Led Transparency Initiative

Authors: Christopher M Whaley, Rose Kerber, Daniel Wang, Aaron Kofner, and Brian Briscombe
Date: 12/1/2024
Resource Type: Gray literature
The study compares the levels and variations in hospital prices that commercial health insurers and Medicare pay, finding that commercial insurers typically pay hospitals far more than Medicare for the same services.
Details
Publisher/Organization: RAND
Payer: Commercial Insurance
Summary: This study uses 2020-2022 commercial claims data from self-insured employers, state all-payer claims databases, and private health plans to analyze hospital prices. It finds that average private insurer prices were 254% of Medicare rates in 2022, with prices exceeding 300% of Medicare in some states. Hospital outpatient procedure prices averaged 263% of Medicare rates, and facility fees accounted for about 87% of outpatient spending. The researchers also find that prices at ambulatory surgery centers averaged 171% of Medicare rates. In addition, prices for private insurers averaged 281% of average sales price for hospital administered drugs, compared with Medicare's payment rate of 106% of average sales price.
Funding Disclosure: The Robert Wood Johnson Foundation and participating employers provided funding for this work.
Topic Areas: Payment Differentials, Vertical Integration, Facility Fees
Citation: Whaley CM, Kerber R, Wang D, Kofner A, Briscombe B. Prices Paid to Hospitals by Private Health Plans: Findings from Round 5.1 of an Employer-Led Transparency Initiative. RAND; December 10, 2024. https://www.rand.org/pubs/research_reports/RRA1144-2-v2.html.

Hospital Facility Fee Report

Authors: Colorado Department of Health Care Policy and Financing
Date: 10/1/2024
Resource Type: Government Report
Commercial and Medicare data from the Colorado All-Payer Claims Database shows outpatient facility fees grew annually from 2017-2022, while professional fee amounts were similar between hospital-affiliated and independent providers.
Details
Publisher/Organization: Colorado Hospital Facility Fee Steering Committee
Payer: Commercial Insurance, Medicare
Summary: The Colorado Hospital Facility Fee Steering Committee analyzed outpatient facility fee trends in Medicare and the commercial market using 2017-2022 data. Total outpatient facility fee reimbursements for the commercial market and Medicare grew by 6.5% per year on average. In the commercial market, professional fee payments for the 25 most frequently billed, high-reimbursement CPT codes were nearly identical for hospital-affiliated and independent providers. However, hospital outpatient departments (HOPDs)charged additional facility fees for these codes. Variations in billing practices across providers—along with incomplete facility fee data for self-funded plans—prevented the Committee from calculating total costs of care for HOPD services, limiting direct comparisons with office-based settings.
Funding Disclosure: N/A
Topic Areas: Payment Differentials, Facility Fees
Citation: Colorado Department of Health Care Policy and Financing. Hospital Facility Fee Steering Committee. Colorado Department of Health Care Policy and Financing; https://hcpf.colorado.gov/sites/hcpf/files/Final%20Hospital%20Facility%20Fee%20Report%20-%20R.pdf.

Hospital Outpatient Prices Far Higher, Rising Faster than Physician Sites

Authors: Blue Health Intelligence
Date: 12/1/2023
Resource Type: Gray literature
The issue brief shows that commercial prices for outpatient services are substantially higher and growing faster in hospital outpatient departments than in ambulatory surgery centers or physician offices, supporting site-neutral payment policies.
Details
Publisher/Organization: Blue Health Intelligence
Payer: Commercial Insurance
Summary: Using national commercial claims data for roughly 123 million people between 2017 and 2022, researchers found that allowed costs for thousands of outpatient services were consistently higher when provided in hospital outpatient departments (HOPDs) than in ambulatory surgery centers (ASCs) or physician offices. HOPD prices also grew more rapidly over time than prices in ASCs or offices. The brief concludes that implementing site-neutral payments would generate substantial savings for patients, employers, and insurers by reducing these price disparities.
Funding Disclosure: The Blue Cross Blue Shield Association provided funding for this work.
Topic Areas: Facility Fees, Payment Differentials, Site-Neutrality
Citation: Blue Health Intelligence. Hospital Outpatient Prices Far Higher, Rising Faster than Physician Sites. Blue Health Intelligence; December 14, 2023. https://www.bcbs.com/news-and-insights/white-paper/ambulatory-payment-classifications-site-neutral-analysis

Facility Fees 101: What Is All the Fuss About?

Authors: Linda J Blumberg and Christine H Monahan
Date: 8/1/2023
Resource Type: Gray literature
The article explains what facility fees are, why they have become more common, and how they increase costs for patients and insurers in the commercial market.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Commercial Insurance
Summary: This article provides an overview of outpatient facility fees, including when hospitals charge them. The article explains that facility fees have become more common as hospitals acquire more physician practices. This trend is driving up overall costs for commercial insurers and increasing out-of-pocket expenses for consumers. The article outlines policy options to reduce site-of-service price differentials and protect consumers in the commercial market, including facility fee prohibitions and site-neutral payment reforms.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Facility Fees, Vertical Integration
Citation: Blumberg LJ, Monahan CH. Facility Fees 101: What is all the Fuss About?. Health Affairs Forefront; August 4, 2023. doi:10.1377/forefront.20230802.247953

Protecting Patients from Unexpected Outpatient Facility Fees: States on the Precipice of Broader Reform

Authors: Christine H Monahan, Karen Davenport, and Rachel Swindle
Date: 7/1/2023
Resource Type: Gray literature
Through analysis of state laws and interviews, the report finds that outpatient facility fees create confusion, but laws in some states are regulating outpatient facility fee billing practices.
Details
Publisher/Organization: Center on Health Insurance Reforms
Payer: Commercial Insurance
Summary: Drawing on analyses of laws in eleven states and more than 40 qualitative interviews with stakeholders, the report details how facility fee billing practices contribute to consumer confusion, opacity in claims data, and difficulties accurately identifying where and how care is delivered. The report also assesses a range of state strategies to regulate outpatient facility fee billing, including facility fee prohibitions, consumer out-of-pocket cost protections, consumer disclosure and other transparency requirements, and hospital reporting requirements.
Funding Disclosure: West Health provided funding for this work.
Topic Areas: Policy Reforms, Facility Fees
Citation: Monahan CH, Davenport K, Swindle R. Protecting Patients from Unexpected Outpatient Facility Fees: States on the Precipice of Broader Reform. Georgetown University Center on Health Insurance Reforms; July 2023. https://facilityfeereform.chir.georgetown.edu/wp-content/uploads/Full-Report-Protecting-Patients-from-Unexpected-Outpatient-Facility-Fees-2023.pdf

Environmental Scan on Consolidation Trends and Impacts in Health Care Markets

Authors: Jodi L Liu, Zachary M Levinson, Annetta Zhou, Xiaoxi Zhao, PhuongGiang Nguyen, and Nabeel Qureshi
Date: 9/1/2022
Resource Type: Gray literature
The environmental scan finds that hospital-physician integration raises health care prices and spending largely by shifting care to higher-cost settings, which can often bill both professional and facility fees.
Details
Publisher/Organization: RAND
Payer: Commercial Insurance, Medicare, Medicaid
Summary: The authors reviewed ten studies examining the price impact of vertical integration between hospitals or health systems and physicians. Eight studies reported price increases, one found no significant effect, and one reported mixed results. A major factor driving higher prices in vertically integrated entities is the shift of services to higher-cost settings where systems can bill both professional and facility fees. Similar to most of the studies on the price effects of vertical integration, nine studies found increases in medical spending associated with vertical integration.
Funding Disclosure: The U.S. Department of Health and Human Services Office of the Assistant Secretary for Planning and Evaluation provided funding for this work.
Topic Areas: Vertical Integration, Facility Fees, Payment Differentials
Citation: Liu JL, Levinson ZM, Zhou A, Zhao X, Nguyen P, Qureshi N. Environmental scan on consolidation trends and impacts in health care markets. RAND Corp; RR-A1820-1; September 30, 2022. https://www.rand.org/pubs/research_reports/RRA1820-1.html

Hospital and Regional Characteristics Associated with Emergency Department Facility Fee Cash Pricing

Authors: Morgan A Henderson and Morgane C Mouslim
Date: 7/1/2022
Resource Type: Peer-reviewed article
The study shows emergency department facility fees for self-pay patients vary widely across hospitals and regions, with higher prices linked to for-profit status and higher bed counts.
Details
Publisher/Organization: N/A
Payer: N/A
Summary: This study examines variations in emergency department facility fees for self-pay patients across hospital and regional characteristics in 2021. The median cash price for emergency department facility fees ranged from about $161 for low-acuity visits to $1,097 for high-acuity visits. Hospitals with for-profit ownership and those with higher bed counts tended to post significantly higher cash prices for facility fees across all visit levels. Meanwhile, hospitals in counties with higher poverty rates generally posted lower cash prices.
Funding Disclosure: The University of Maryland provided funding for this work.
Topic Areas: Facility Fees
Citation: Henderson MA, Mouslim MC. Hospital And Regional Characteristics Associated With Emergency Department Facility Fee Cash Pricing. Health Aff (Millwood). 2022;41(7):1029-1035. doi:10.1377/hlthaff.2022.00045

The Association Between Hospital-Physician Vertical Integration and Outpatient Physician Prices Paid by Commercial Insurers: New Evidence

Authors: James Goodwin, Daniel R Arnold, Brent D Fulton, and Richard M Scheffler
Date: 3/1/2021
Resource Type: Peer-reviewed article
The study finds that hospital-physician vertical integration is associated with modest increases in office visit prices for some specialties in the commercial market, but not with greater use of facility fees.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance
Summary: This study analyzes over 30 million office visit claims from commercial insurers between 2012-2016 to examine the relationship between hospital-physician vertical integration and prices and facility fees. It finds that higher levels of vertical integration were associated with increases in physician prices for select specialties. For example, a 10% increase in hospital-physician integration was linked to 0.5%-1.0% price increases for primary care, orthopedics, and cardiology office visits. The geographic areas with the greatest growth in vertical integration also had the greatest price increases over the study period. The study finds no association between vertical integration and facility fee billing practices for office visits.
Funding Disclosure: The Agency for Healthcare Research and Quality provided funding for this work.
Topic Areas: Vertical Integration, Facility Fees
Citation: Godwin J, Arnold D, Fulton B, Scheffler R. The Association Between Hospital-Physician Vertical Integration and Outpatient Physician Prices Paid by Commercial Insurers: New Evidence. INQUIRY: The Journal of Health Care Organization, Provision, and Financing. 2021;58. doi:10.1177/0046958021991276

The Increasing Financial Burden of Outpatient Elective Surgery for the Privately Insured

Authors: Jessica I Billig, Wen-Ching Lan, Kevin C Chung, Chang-Fu Kuo, and Erika D Sears
Date: 9/1/2020
Resource Type: Peer-reviewed article
Outpatient surgery payment rose sharply from 2011-2017, driven by higher facility fees and out-of-pocket expenses, while professional fees remained flat.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance
Summary: This study examines more than 5.2 million outpatient surgeries among commercially insured patients to assess trends in total payments, facility fees, professional fees, and out-of-pocket (OOP) expenses. Total payments for surgical encounters increased by 29%, primarily due to a 53% rise in facility fees, while professional fees remained stable. Patient OOP expenses grew by 50%. Predicted payments for procedures in ambulatory surgery centers and hospital outpatient departments were higher than office-based procedures, adding $2019-$2649 in total payments and $302-$324 in OOP expenses per procedure.
Funding Disclosure: The Department of Veterans Affairs Office of Health Services Research and Development provided funding for this work.
Topic Areas: Facility Fees, Payment Differentials
Citation: Billig JI, Lan W, Chung K, Kuo C, Sears E. The Increasing Financial Burden of Outpatient Elective Surgery for the Privately Insured, Ann Surg. September 2020. 01;272(3):530-536. doi:10.1097/SLA.0000000000004201

Hospital Prices Grew Substantially Faster than Physician Prices for Hospital-Based Care in 2007-14

Authors: Zack Cooper, Stuart Craig, Martin Gaynor, Nir J Harish, Harlan M Krumholz, and John Van Reenen
Date: 2/1/2019
Resource Type: Peer-reviewed article
The study finds that from 2007-2014, the price of the hospital component of hospital-based outpatient care in the commercial market grew much faster than the price of the physician component, accounting for most of the price growth.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance
Summary: Using negotiated rates from three commercial insurers from 2007 to 2014, the study compares price growth for the hospital and physician components of hospital-based outpatient services. The price of the hospital component grew by 25% over this period, and the price of the physician component grew by 6%. The hospital component comprised 79.5% of the total price for outpatient procedures. Because hospital prices grew faster and accounted for a larger share of costs, the hospital component accounted for 93.5% of the increased total price for outpatient services.
Funding Disclosure: The National Institute for Health Care Management Foundation and the Commonwealth Fund provided funding for this work.
Topic Areas: Payment Differentials, Facility Fees
Citation: Cooper, Z, Craig S, Gaynor M, Harish N, Krumholz H, van Reenan J. Hospital Prices Grew Substantially Faster than Physician Prices for Hospital-Based Care in 2007-2014. Health Affairs 38, No 2 (2019): 184-189. doi:10.1377/hlthaff.2018.05424

The Effect of Hospital Acquisitions of Physician Practices on Prices and Spending

Authors: Cory Capps, David Dranove, and Christopher Ody
Date: 5/1/2018
Resource Type: Peer-reviewed article
The study finds that hospital acquisitions of physician practices increase service prices by 14% and total enrollee spending by 5% in the commercial insurance market.
Details
Publisher/Organization: N/A
Payer: Commercial Insurance
Summary: This study analyzes commercial insurance claims from 2007 to 2013 for patients treated by physician practices before and after hospitals acquired them. After adjusting for patient characteristics and market factors, hospitals increased prices for services at acquired physician practices by 14.1% and raised total enrollee spending by 4.9%. Price increases were largest in markets where hospitals had greater market share, reflecting increased bargaining power for negotiated reimbursement and the new application of facility fees. New facility fees accounted for about 45% of the increase in prices.
Funding Disclosure: The authors did not disclose funding for this work.
Topic Areas: Vertical Integration, Facility Fees
Citation: Capps C, Dranove D, Ody C. The Effects of Hospital Acquisitions of Physician Practices on Prices and Spending. J Health Econ. 2018 May;59:139-152. doi:10.1016/j.jhealeco.2018.04.001.
Results Found: 29