| Course | HA 610 Health Policy and Management |
|---|---|
| Unit | Unit 4 |
| Paper type | Stakeholder position paper |
| Length | About 820 words, 5 pages |
| Format | APA 7 student paper |
| School | Herzing University |
| Program | MS in Healthcare Administration |
| Updated | October 2026 |
Free sample paper for HA 610 Unit 4
Prices in Dollars, With Time to Get There: A Community Hospital's Position on Writing Hospital Price Transparency Into Federal Law
Student Name
Health Care Administration, Herzing University
HA 610: Health Policy and Management
Instructor Name
February 6, 2026
Prices in Dollars, With Time to Get There: A Community Hospital's Position on Writing Hospital Price Transparency Into Federal Law
Our Position
[Composite] Community Hospital, a 180-bed nonprofit hospital serving a mixed rural and small-city county, supports federal legislation that would put hospital price transparency into statute and require negotiated prices to be shown as dollar amounts, provided the law allows a phased timeline of at least two years for contracts that currently pay by percentage and applies penalties only after a hospital has had a chance to correct a finding.
We take this position because the current approach, in which hospitals may post a percentage or formula and add statistical allowed-amount data, satisfies the rule without telling patients or employers what they will pay. The version of the Lower Costs, More Transparency Act that passed the House in 2023 required negotiated charges "expressed as a dollar amount" (Lower Costs, More Transparency Act, 2023). We agree with that direction. We are signing this paper as an institution because we will carry the obligations we are asking Congress to impose.
The Stakeholder Map
Each stakeholder is listed with what it wants, what it can do about it, and how much it stands to gain or lose from dollar-amount transparency written into law.
| Stakeholder | What it wants | What it can do | Stands to gain or lose |
|---|---|---|---|
| Patients, especially those with high deductibles or no coverage | A price they can rely on before care | Choose where to receive planned care; complain to regulators; tell their stories to legislators | Gain: usable prices. Risk: posted prices still differ from what they are billed if insurance rules are not clear |
| Employers that buy coverage | Negotiated rates in a form they can compare across hospitals | Redesign plans; steer employees; lobby through business groups | Gain substantially: dollar figures allow direct comparison |
| Insurers | Protection of negotiated terms they regard as competitive information | Lobby against disclosure; resist renegotiation to fixed rates | Lose some bargaining secrecy; gain if competing plans must disclose too |
| Physicians and nurses on staff | Fewer billing complaints; less time answering price questions | Support or oppose through medical staff and professional groups | Modest gain; little direct cost |
| State agencies (insurance department, health department) | Enforcement that does not duplicate or contradict state laws | Add state requirements; coordinate enforcement | Neutral to positive if federal and state rules align |
| Our hospital | Clear rules, enough time, and fair enforcement | Comply, testify, comment on rules, renegotiate contracts | Lose: conversion cost and penalty exposure. Gain: trust, fewer disputes, better employer relationships |
Why Dollars Matter
The evidence that current transparency falls short is consistent. A national study found that more than half of general acute-care hospitals had not posted a file with commercial negotiated prices five months after the federal rule took effect (Jiang et al., 2022). Among hospitals that do post prices, researchers who compared 60 hospitals found that online and telephone prices for the same shoppable service frequently differed, and many hospitals did not give both (Thomas et al., 2023). A percentage of billed charges cannot be compared across hospitals, because the billed charge itself varies. A dollar amount can.
Federal regulation is moving in the same direction. For 2026, CMS requires hospitals that use percentage-based rates to add median and percentile allowed amounts derived from remittance data, and to have a named senior official vouch for the file in a signed attestation (Centers for Medicare & Medicaid Services [CMS], 2025). This helps, but a range of past allowed amounts is still not a price a patient can plan around. Statute would also give the requirement a firmer footing than regulation alone.
Why We Ask for Time
Five of our fourteen commercial contracts pay some services as a percentage of charges. Converting those terms to dollar figures for every item and service means renegotiating contracts or building a recurring calculation that we would then attest to. Renegotiation takes place at renewal, and our contracts renew on different dates over the next two years. A requirement effective in a single year would force us to calculate dollar figures from terms that were never designed to produce them, with a senior official attesting to their accuracy. A two-year phase-in for percentage-based contracts would let us move to fixed rates at renewal, which is the better outcome for everyone on the map.
Why We Ask for Correction Before Penalty
The House-passed bill set maximum penalties that increase with bed count and increase again after a year of noncompliance, and it required the Secretary to review each hospital's compliance at least every three years (Lower Costs, More Transparency Act, 2023). We support penalties that scale with size. We ask that they follow a notice and a reasonable correction period in every case, as the bill largely provided, because errors in a file covering every item and service are inevitable and the purpose is accurate information, not penalty revenue.
Where We Expect Disagreement
Two groups on the map are likely to disagree with parts of this position, and we take their concerns seriously. Insurers argue that negotiated rates are competitive information and that disclosure could lead to prices converging upward, as lower-priced hospitals learn what others are paid. That risk is real in concentrated markets, and it is one reason we support transparency paired with enforcement of antitrust law rather than transparency alone. Smaller rural hospitals, some of them our referral partners, argue that the cost of compliance falls heavily on organizations without data analysts. We share that concern, which is why our request for a phased timeline and correction before penalty is not only for ourselves. We would support technical assistance or a simplified reporting path for hospitals under 50 beds. Neither disagreement changes our position that patients and employers are entitled to see prices in dollars; both shape how we think the law should get there.
What We Will Do Regardless
Whatever Congress decides, we will move our five percentage-based contracts to fixed-dollar terms at renewal, expand our consumer estimator beyond the required minimum, and publish our financial assistance policy alongside our prices. We would rather be ahead of the law than behind it. The hospital is composite; the sources cited are published.
References
Centers for Medicare & Medicaid Services. (2025). Medicare program: Hospital outpatient prospective payment and ambulatory surgical center payment systems; quality reporting programs; overall hospital quality star rating; hospital price transparency; and notice of closure of a teaching hospital and opportunity to apply for available slots. Federal Register, 90, 53448. https://www.federalregister.gov/d/2025-20907
Jiang, J. X., Polsky, D., Littlejohn, J., Wang, Y., Zare, H., & Bai, G. (2022). Factors associated with compliance to the hospital price transparency final rule: A national landscape study. Journal of General Internal Medicine, 37(14), 3577-3584. https://doi.org/10.1007/s11606-021-07237-y
Lower Costs, More Transparency Act, H.R. 5378, 118th Cong. (2023). https://www.congress.gov/bill/118th-congress/house-bill/5378
Thomas, M., Flaherty, J., Wang, J., Henderson, M., Ho, V., Cuban, M., & Cram, P. (2023). Comparison of hospital online price and telephone price for shoppable services. JAMA Internal Medicine, 183(11), 1214-1219. https://doi.org/10.1001/jamainternmed.2023.4753
What the HA 610 Unit 4 instructions ask for
Unit 4 asks you to write a position paper for an organization on a policy issue, with attention to every stakeholder involved. Expect to state the position, map stakeholders with their interests, influence and stakes, argue each part of the position with evidence, address expected disagreement and say what the organization will do regardless of the outcome. Students often ask how to keep the paper from sounding self-serving. Acknowledge where the organization's interest and the public interest align and where they differ. A stakeholder map with what each party can do makes the politics clear. Take opposing views seriously rather than dismissing them. Committing to action regardless of the outcome adds credibility with legislators.
How the HA 610 Unit 4 example is put together
The paper opens with the position in a few sentences, naming the hospital and what it supports and asks for. The stakeholder map is a table with interests, power and stakes for employers, insurers, patients, the hospital association and legislators. Three argument sections support dollars, time and correction before penalty, each with national evidence and the hospital's own contract data. The disagreement section takes employer coalitions and insurers, states their likely objections fairly and answers them. The commitments section lists steps the hospital will take no matter what Congress does, such as converting percentage contracts at renewal. The paper balances advocacy with candor, which makes it persuasive to readers who expect hospitals to argue their own interest. Patients appear on the map as the group the policy is meant to serve.
HA 610 Unit 4 rubric: what full points look like
Herzing's rubric for a stakeholder position paper typically covers the position, the stakeholder map, evidence for each argument, treatment of opposing views and commitments. Treatment of opposing views and the stakeholder map carry the most weight, because a position that ignores other parties will not persuade the people who decide. Position points reward a clear, specific stance. Map criteria look for interests, power and stakes for each party. Evidence earns credit when national studies and local data support each claim. Commitments are often credited because they show good faith beyond self-interest. Professional, measured tone is expected. Jiang's compliance study and the House bill's penalty provisions support the arguments.
Common HA 610 Unit 4 mistakes, and how to avoid them
Position papers in HA 610 Unit 4 commonly lose points by arguing only the organization's interest. Another frequent problem is a stakeholder list without interests or power. Students often skip opposing views or describe them unfairly. Evidence is local only or national only. Commitments are missing, so the position reads as a request for delay. The position is vague, such as supporting transparency in principle. Patients, the group the policy serves, are left off the map. Penalty provisions are discussed without numbers. Finally, take the other side seriously, because graders reward a paper that persuades people who start out disagreeing.
Get a HA 610 Unit 4 example written to your instructions
Send the Unit 4 instructions and the rubric from your HA 610 classroom, plus the policy question and the organization whose position the paper speaks for. We write a custom example with the interests mapped, the position defended on stated grounds and the opposing case answered, returned in 24 to 48 hours. The first custom sample is free.
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HA 610 Unit 4 questions, answered
Can the position be one I personally disagree with?
Yes, and it is often the better exercise. The paper speaks for an organization, so the argument has to hold together from that organization's interests rather than from yours. Writing a position you find uncomfortable forces you to state the opposing case accurately, which is exactly the skill the assignment measures. Keep your own view out of the document itself.
How many stakeholders belong in the map?
Enough to cover everyone with real exposure and no more. Five or six parties with genuine interests, described in detail, beat a list of a dozen names given a line each. If a party cannot affect the outcome and is not affected by it, the map is stronger without them, and the space goes to the parties who can block or carry the policy.
Is a position paper the same as an opinion piece?
They share a spine and differ in evidence. An opinion piece persuades a general audience quickly, while a position paper is a standing document that other professionals will read closely and cite, so every claim carries a source and the opposing case gets stated fairly. Check your rubric for citation expectations, which usually match the rest of the course.
Where can I find a free HA 610 Unit 4 sample paper?
Read the complete HA 610 Unit 4 position paper here at no charge, a hospital's stance on price transparency with a stakeholder map. Ask for a custom paper on another policy question.
Why do hospitals ask for more time on price transparency rules?
Some payer contracts pay as a percentage of charges, so dollar prices must be calculated or contracts renegotiated. This sample explains that reason while committing the hospital to dollar prices.