The cost of medical care can vary significantly depending on where a patient receives treatment

Independent clinics often offer lower, more predictable pricing, while hospital-based practices charge higher facility fees, co-payments, and deductibles. Yet, patients are rarely aware of these differences, leading to unexpected costs and financial strain.

Understanding these pricing discrepancies is necessary for informed healthcare decisions

This analysis explores the impact of price transparency in healthcare and why patients deserve clear, upfront information about the cost of their care. In Virginia, Certificate of Public Need (COPN) regulations restrict the entry of new ASCs into the market, limiting competition and reducing the availability of lower-cost care settings, particularly in high-cost regions such as Northern Virginia. 

Distribution of ASC (Independent) & HOD (Hospital Based) Diagnostic Centers in Northern Virginia

• This visual highlights the disparity in access of diagnostic care centers (independent, hospital-based, Kaiser).
• There are nearly five times more hospital-based centers than independent practices
• Notice how wealthier counties tend to be more populated with hospital-owned facilities.

Cost Comparison for Diagnostic Codes ASC (Independent) vs. HOD (Hospital-Based) in Northern Virginia

Cost Comparison for Surgical Codes ASC (Independent) vs. HOD (Hospital-Based) in Northern Virginia

Data Source: Procedure Price LookUp – Medicare.gov
Created By: Shreeyukti Rana, Health Informatics Intern ’26

• This visual presents the cost breakdown for surgical procedures, comparing the charges of independent and hospital-based centers per diagnostic code for 2025.
• It is significant to mention: While the facility fees and patient co-pay increases, doctors’ fee charges remains the same.

Hospital Outpatient Department (HOPD) Charge Trend (2020-2024) 

Data Source: Procedure Price LookUp – Medicare.gov
Created By: Shreeyukti Rana, Health Informatics Intern ’26

• This chart tracks the facility fee charged at H0spital Outpatient Department (HOPD) across procedure groups.
• HOPD facility fees are consistently and significantly higher than those at Ambulatory Surgical Centers (ASCs), often 2x to 5x more for the same procedure.
• This view is designed to surface the procedures where HOPD charges are growing or disproportionately high, helping identify where site-of-care steering can deliver the greatest financial benefit for both payers and patients.

Facility Fee Gap ASC (Independent) vs. HOD (Hospital-Based) in Northern Virginia

Data Source: Procedure Price LookUp – Medicare.gov
Created By: Shreeyukti Rana, Health Informatics Intern ’26

• This chart isolates the gap between the HOPD and ASC facility fees for each procedure
• The dollar difference patients and payers absorb simply due to where a procedure is performed, not what is performed.
• Because the physician fee is identical in both settings, this gap is purely a function of the facility setting.

Projected Savings in Total Cost by Shifting Cases to ASCs (Independent) 

Data Source: Procedure Price LookUp – Medicare.gov
Created By: Shreeyukti Rana, Health Informatics Intern ’26

• This chart highlights the potential cost savings achieved by shifting procedures from an HOPD to an ASC, organized by procedure category.
• Savings are calculated as the difference in total cost between settings and reflect both what Medicare pays and what the patient owes in copays.
• Categories such as Breast Repair / Reconstruction and Therapeutics show the largest opportunities for cost reduction, making this view useful for prioritizing high-impact site-of-care decisions.

Projected Annual Savings by Different Levels of Case Shift to ASCs (Independent) (25% – 100%)

Data Source: Procedure Price LookUp – Medicare.gov
Created By: Shreeyukti Rana, Health Informatics Intern ’26

• Full substitution is not required to generate meaningful savings — even redirecting just 25% of HOPD procedures to ASCs produces $341M in annual savings by 2029.
• A moderate 50% shift yields $682M per year, demonstrating that significant financial relief is achievable well before complete site-of-care reform.
• Every year, COPN regulations delay ASCs’ expansion; this savings opportunity grows larger as hospital outpatient charges continue to climb.

Projected Annual and Cumulative Total and Patient Cost Savings from Shifting Care from HOD (Hospital-Based) to ASC (2024–2029)

Data Source: Procedure Price LookUp – Medicare.gov
Created By: Shreeyukti Rana, Health Informatics Intern ’26

• Shifting surgical procedures from HOPD to ASC could save the healthcare system over $1.3 billion annually by 2029, up from $604 million in 2024.
• Patients directly benefit too, with out-of-pocket copay savings growing from $120.8M to $272.8M over the same period.
• Over six years, the cumulative savings opportunity totals $5.6 billion — a gap that widens every year HOPD prices continue rising unchecked.

Semi-Annual Hospital Price Transparency Compliance Report – November 2024

Check which hospitals are compliant with the federal hospital price transparency rule under the authority of the Affordable Care Act (ACA).

“The program seeks to contain health care costs while ensuring financial viability and access to health care for all Virginia at a reasonable cost.”

– Virginia Department of Health

What is COPN and why should you care?

• What it is: A state permit required before opening or expanding a healthcare facility. In Virginia, the application fee alone can reach $20,000 — with no guarantee of approval.
• How it works in practice: Existing hospital systems can formally oppose a competitor’s application. The review process takes years. Independent ASCs in wealthy markets — where hospitals profit most — have the hardest time winning approval.
• What the state says vs. what the data shows: VDH claims COPN “contains costs and ensures access.” The data on this page shows costs have risen, and independent access points are scarce in exactly the markets that need competition most.

Reality:

• In Virginia, the application filing fee can cost up to $20,000 without a guarantee of approval.
• In the Commonwealth, COPN laws have incentivized large hospital systems to monopolize outpatient diagnostic imaging and surgical services by restricting competition among non-hospital/independent providers, particularly in affluent markets, such as Northern Virginia.

Implications:

Action:

• Beyond cost, specifically in Northern Virginia, COPN regulation has given hospital systems the latitude to create monopolies and thwart competition in communities where they have dominant market presence. Legislators should seriously consider removing the COPN regulation.
• Encourage the initiation of lower-cost facilities
• Expand independent access points of care.

Impact of increasing diagnostic and surgical services in hospital-based facilities

Single

• 2023 Total Annual Premium: $8,144.
• 50.5% increase from 2013 to 2023 in Total Annual Premium.

Family

• 2023 Total Annual Premium: $24,251.
• 52.4% increase from 2013 to 2023 in Total Annual Premium.

Moving the bar to the left unveils the average annual single premium.

Moving the bar to the right unveils the average annual family premium.

Figure 1 & 2. Kaiser Family Foundation

Executive Order on Healthcare Price Transparency  

On February 25, the White House issued an Executive Order to improve healthcare price transparency, ensuring patients have access to clear, accurate, and actionable pricing information.

In response, the Departments of the Treasury, Labor, and Health & Human Services will:

• Require hospitals and insurers to disclose actual prices—not estimates—including for prescription drugs.
• Strengthen enforcement to ensure compliance with price transparency regulations.

Resources for Hospitals

CMS offers tools to assist with compliance:

• Hospital Price Transparency Tools – Includes an Online Validator to check machine-readable files and the HPT TXT Generator for required data formatting.
• Data Dictionary (GitHub Repository) – Provides templates, technical instructions, and support for encoding pricing data.

Hospital Price Transparency Requirements

Under existing CMS regulations, hospitals must provide:

• A machine-readable file listing standard charges for all items and services.
• A consumer-friendly display of shoppable services for easy comparison.

Compliance & Enforcement

CMS is enhancing its monitoring and enforcement efforts in line with the Executive Order. Non-compliance will result in swift action, with enforcement activities and outcomes published quarterly.

For additional guidance, email PriceTransparencyHospitalCharges@cms.hhs.gov.

Take Action!

Every patient deserves access to clear and accurate healthcare pricing. If you believe in holding hospitals and insurers accountable, now is the time to act!

Contact your legislator and urge them to support stronger price transparency enforcement.

• Find your representative – Enter your home zip-code to find your Virginia Senate and House legislators. 

• Sign the petition – We’ll submit petitions monthly to amplify our voices.

Your voice matters—let’s push for real change together!

Additional Resources:

Virginia Senate Committee on Health 2026

Virginia House Sub Committee on Health 2026