MSNVA PTR4 – MSNVA

Centers for Medicare & Medicaid Services (CMS) Price Transparency Report 4.0

A Site-of-Service Price Analysis and Savings Projection Between Ambulatory Surgical Centers (ASCs) and Hospital Outpatient Departments (HOPDs) in Northern Virginia

Bringing attention to the pricing discrepancies between independent and hospital-based facilities for the same levels of care

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 to lowers cost (independent) diagnostic care centers.
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.
Data Source:
Health Systems Agency of Northern Virginia
CT/MRI Reports 2020

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

This visual presents the cost breakdown for procedures, comparing the charges of independent and hospital-based centers per diagnostic code across 2024 and 2025.
Data source:
Medicare Price Lookup Tool

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

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.

Data Source & Credits:
Virginia Health Information
Medicare Price LookUp Tool
Created by: Shreeyukti Rana, Health Informatics Intern, Spring’26
Updates by: Jacob Abdeen, Data Analytics Intern, summer’26

Projected Savings at ASC (Independent) Sites, Based on 1,000 Procedures

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.

Data Source & Credits:
Medicare Price LookUp Tool
Created by: Shreeyukti Rana, Health Informatics Intern, Spring’26
Updates by: Jacob Abdeen, Data Analytics Intern, summer’26

Total Projected ASC Savings by Category – Based on 1,000 Cases per CPT Code (Total: 2.57B)

This chart shows the estimated projected savings by procedure category using the 1,000-case assumption for CPT code. The total projected savings for 1,000 cases is shown in the center, while the outer segments display how those savings are distributed across 7 procedure groups.

Data Source & Credits:
Medicare Price LookUp Tool
Created by: Jacob Abdeen, Data Analytics Intern, Summer’26

COPN - Certificate of Public Need

“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:

COPN regulation has failed to reduce unnecessary healthcare spending. Instead, it has increased costs of outpatient diagnostic and surgical services.
Systematically given large hospitals and health systems the power to eliminate competition by allowing them to oppose projects they view as a threat to their existing services.

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 hospital-based facility fees on Insurance Premiums

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

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.