Practice Management

Folks – I know the No Surprises Act activities are new to all of us, but I am wondering how groups are managing the Coolin-Off Period. I'm following this direction:

During the 90-day period after the certified IDR entity's decision (referred to as the "cooling off period") the party that initiated the IDR process may not initiate a subsequent IDR process involving the same payer and same or similar item or service

Groups are  seeing large backlogs of claims that building as they wait through the Colling-Off Period delaying revenue even further. Any insights, comments or suggestions on how to best deal with this issue?

Keith E. Chew, MHA, CMPE, FRBMA

Principal

Consulting with Integrity

18 Hawks Nest

Chatham, IL     62629

217-971-5293

HI Keith

I don't think there is any way around it.  My strategy has been to continue to initiate new open negotiation notices for those services in an effort to bring the payor to the negotiating table.  Our experience has been that if we can get the payor to negotiate the agreement can include resolution of all pending disputes during the out of network period.

The major problem now is that no new batch disputes are being accepted by the IDR's in the wake of the most recent Texas Medical Association lawsuits, so we can't initiate new IDR disputes even after the cooling off period ends.  I have several for which the cooling off period has ended, but we can go back to the IDR.  The way the time frames work, batches which accumulate during the cooling off period are significantly larger, and therefore I think they are more likely to get the payors attention when we win, so I don't think the cooling off period is a bad thing if we can get the process moving.

I would not think there would be a major cash flow impact from the cooling off period, since what you're talking about is delaying receipt of the difference between the initial payment and whatever you might gain from an IDR decision, less the administrative fee. 

As you may know, CMS recently published proposed rules regarding the IDR process to address the most recent TMA decisions, which in my opinion are quite problematic (most significantly a 25 case limit on batch disputes).  I believe RBMA will be writing comments.  If anyone has ideas about how to make the process work better, please share them so we can incorporate those ideas into RBMA comments.

Dave

       David Smith, FACMPE  |  Executive Director  |  785.393.8387

5800 Foxridge Dr.  Ste 240  |  Mission, KS  66202  |  www.uickc.com

                                                          Member of

Folks – I know the No Surprises Act activities are new to all of us, but I am wondering how groups are managing the Coolin-Off Period. I'm following this direction:

During the 90-day period after the certified IDR entity's decision (referred to as the "cooling off period") the party that initiated the IDR process may not initiate a subsequent IDR process involving the same payer and same or similar item or service

Groups are  seeing large backlogs of claims that building as they wait through the Colling-Off Period delaying revenue even further. Any insights, comments or suggestions on how to best deal with this issue?

Keith E. Chew, MHA, CMPE, FRBMA

Principal

Consulting with Integrity

18 Hawks Nest

Chatham, IL     62629

217-971-5293

Folks – I know the No Surprises Act activities are new to all of us, but I am wondering how groups are managing the Coolin-Off Period. I'm following this direction:

During the 90-day period after the certified IDR entity's decision (referred to as the "cooling off period") the party that initiated the IDR process may not initiate a subsequent IDR process involving the same payer and same or similar item or service

Groups are  seeing large backlogs of claims that building as they wait through the Colling-Off Period delaying revenue even further. Any insights, comments or suggestions on how to best deal with this issue?

Keith E. Chew, MHA, CMPE, FRBMA

Principal

Consulting with Integrity

18 Hawks Nest

Chatham, IL     62629

217-971-5293

Keith!  Thank you for sharing.  You have always added such great wisdom in RBMA.

Regarding your question about this 90 day cooling off period and needless backlogs,  I think that is the point of people/lobbyist  that got this put into the NSA. 

The insurance companies win and the physicians lose, when  this backlog is created.     I think the question that needs to be asked:  What is the reason for the cooling off period?  Why was this added into the process.   Is it providing any benefit for the overall goal or is it just there to help cause a backlog which benefits one side. 

For anything we do in life, I try to ask the question:  at what cost?  I know there is a big cost to the physician side.  Which means it's a gain for the insurance side.  From a  marketing perspective, A plus on sounding great,  "cooling off period."

I think that SOUNDS almost  as good as the 30 day negotiation period prior to going to mediation.   My experience with this 30 day negotiation period prior to mediation, I have seen an insurance company hire sub-contractors who don't have any authority to negotiate. 

They offer the same price as we were paid when we originally filed the claim.     It is that price which is why we filed to go to mediation.  

Maybe this is just my unique experience. Nothing like the appearance of things and the actuality. 

Physician shortages are going to get even worse if the lobbyist win and the system keeps favoring those without this much post college schooling. 

Would love to hear others experience. Keith, thanks for writing in!!!

Gayle

Gayle Schreier, MBA

Business Manager

Roper Radiologists, PA

316 Calhoun Street

Charleston, SC  29401

Gayle.schreier@rsfh.com

843-724-2015

Folks – I know the No Surprises Act activities are new to all of us, but I am wondering how groups are managing the Coolin-Off Period. I'm following this direction:

During the 90-day period after the certified IDR entity's decision (referred to as the "cooling off period") the party that initiated the IDR process may not initiate a subsequent IDR process involving the same payer and same or similar item or service

Groups are  seeing large backlogs of claims that building as they wait through the Colling-Off Period delaying revenue even further. Any insights, comments or suggestions on how to best deal with this issue?

Keith E. Chew, MHA, CMPE, FRBMA

Principal

Consulting with Integrity

18 Hawks Nest

Chatham, IL     62629

217-971-5293

Gayle – I think you have some very solid questions. I know that there are a number of issues with the NSA that cause indigestion and that the RBMA, ACR and Texas Medical Society to name a few have been working on with positive results.  We may be able to have them focus on this useless provision as the next round of battles..... That would certainly be a great advantage for medical practices across the industry, not just radiology.....

Keith!  Thank you for sharing.  You have always added such great wisdom in RBMA.

Regarding your question about this 90 day cooling off period and needless backlogs,  I think that is the point of people/lobbyist  that got this put into the NSA. 

The insurance companies win and the physicians lose, when  this backlog is created.     I think the question that needs to be asked:  What is the reason for the cooling off period?  Why was this added into the process.   Is it providing any benefit for the overall goal or is it just there to help cause a backlog which benefits one side. 

For anything we do in life, I try to ask the question:  at what cost?  I know there is a big cost to the physician side.  Which means it's a gain for the insurance side.  From a  marketing perspective, A plus on sounding great,  "cooling off period."

I think that SOUNDS almost  as good as the 30 day negotiation period prior to going to mediation.   My experience with this 30 day negotiation period prior to mediation, I have seen an insurance company hire sub-contractors who don't have any authority to negotiate. 

They offer the same price as we were paid when we originally filed the claim.     It is that price which is why we filed to go to mediation.  

Maybe this is just my unique experience. Nothing like the appearance of things and the actuality. 

Physician shortages are going to get even worse if the lobbyist win and the system keeps favoring those without this much post college schooling. 

Would love to hear others experience. Keith, thanks for writing in!!!

Gayle

Gayle Schreier, MBA

Business Manager

Roper Radiologists, PA

316 Calhoun Street

Charleston, SC  29401

Gayle.schreier@rsfh.com

843-724-2015

Folks – I know the No Surprises Act activities are new to all of us, but I am wondering how groups are managing the Coolin-Off Period. I'm following this direction:

During the 90-day period after the certified IDR entity's decision (referred to as the "cooling off period") the party that initiated the IDR process may not initiate a subsequent IDR process involving the same payer and same or similar item or service

Groups are  seeing large backlogs of claims that building as they wait through the Colling-Off Period delaying revenue even further. Any insights, comments or suggestions on how to best deal with this issue?

Keith E. Chew, MHA, CMPE, FRBMA

Principal

Consulting with Integrity

18 Hawks Nest

Chatham, IL     62629

217-971-5293