Manatt Health November 14, 2023
On October 27, the Departments of Health and Human Services (HHS), Labor and the Treasury and the Office of Personnel Management (the Departments) released a proposed rule to revamp certain aspects of the No Surprises Act’s (NSA) independent dispute resolution (IDR) process for out-of-network provider reimbursement. The Departments’ proposal aims to smooth policy and operational road bumps to render more timely IDR determinations and payments, in response to stakeholder concerns.
The proposed rule comes as the volume of disputes far outpaces projections, causing delays in their resolution. The Departments projected in 2022 that there would be 17,000 disputes annually; the proposed rule estimates that 420,000 disputes will be initiated in 2024 (including a reduction of 25 percent they hope the...
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