The American College of Radiology® (ACR®) provided comments Dec. 22, in response to the U.S. Departments of the Treasury, Labor, and Health and Human Services proposed rule related to the federal independent dispute resolution (IDR) process initiated by the No Surprises Act (NSA). The College supports many proposed policy changes to address concerns raised about imaging providers’ access to the IDR process.
Specifically, the proposed rule addresses the failure of payers to communicate IDR eligibility information with payment remittance, financial accessibility of IDR for radiology practices, open negotiation communication issues, cooling off period concerns and IDR entity selection issues. The rule also includes a proposal to reduce the administrative fee for low-dollar claim disputes. These are positive changes recommended by many specialty societies, including ACR. While supporting the proposed changes, the ACR encouraged the departments to consider enforcement mechanisms for payers who do not comply with the statute and regulations.
The College expressed concern with some details within the proposed rule, including limiting batching to 25 line items in a single dispute, and details of the proposal to reduce the administrative fee for low-dollar claims. Imaging services are frequently significantly less than the $150 administrative fee required to be paid to enter the IDR process. Without the ability to submit comprehensive batches, IDR is not economically accessible for the majority of imaging claims. The ACR argues that since certified IDR entities are already permitted to charge additional fees for batches larger than 25 line items, batch limits are unnecessary. Similarly, ACR commented that the proposed reduced administrative fee for low-dollar claims of 50% of the full administrative fee is too high and recommended a reduced administrative fee of no more than $50.
For more information or if you have questions, contact Katie Keysor, ACR Senior Director of Economic Policy.