Dave thanks for keeping tabs on this.
Have not had a chance to read yet, but some of the points you mention are very concerning and are a barrier to arbitration.
For comparative purposes, relative to TX regs
1. can file in batches of $5000 in disputed amount
2. Disputed amount defined as the diff between allowed and full billed.
3. The website would seem to indicate you have to file at the individual dr NPI, however through much discussion and trial and error there are ways to overcome this. I can talk to you off line on this topic.
4. must file within 90 days of the payment date.
5. once filed you have 20 days to negotiate with the payer before it gets assigned to an arbiter and consequently fees are incurred.
6. 5 arbiters are randomly assigned once filed, you can strike 2 of the 5 and the health plan can strike 2.
7. arbiter fees are listed on the TDI website.
8. you can extend the 20 days if both parties agree - we have had to do this multiple times to finish negotiations.
9. each batch of $5000 is a separate arbiter fee.
filing at the CPT code level is pure insanity and allows the payers to get away with anything they want.
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Douglas G. Kraus, CPA
Chief Financial Officer
South Texas Radiology Group, P.A.
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Original Message:
Sent: 10-01-2021 17:35
From: David Smith
Subject: Surprise Billing Arbitration Batching
I am reviewing the second round of No Surprises Act regs issued yesterday. A question for those with a state process that allows batching of claims: what are the limitations on batching in your state? If you have used the process, have those limitations presented a problem? If you have to file multiple batches with the same payor, is the arbitration fee the same for each, or is there a volume discount for related disputes with similar facts?
The proposed federal regs require that each CPT code be batched separately, which seems too restrictive and could potentially be prohibitively expensive for all but high volume codes. The federal rules say you can batch 30 days worth of claims for the same CPT code (90 if during the "suspension period").
Wondering what states are doing.
Thanks
Dave
David Smith, FACMPE | Executive Director | 785.393.8387
5800 Foxridge Dr. Ste 240 | Mission, KS 66202 | www.uickc.com
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