Feds Implement New Process for Resubmitting Independent Dispute Resolution Claims, Allow Payers an Additional Six Months for QPA Recalculations

The U.S. Departments of Health and Human Services, Labor, and the Treasury recently announced a new process within the No Surprises Act for parties to resubmit independent dispute resolution (IDR) claims that were originally submitted improperly. Under the new automated process, the federal IDR portal will send disputing parties a unique webform to resubmit disputes that were originally improperly submitted, instead of parties receiving a request from the certified IDR entity.

Effective May 1, parties to disputes eligible to be resubmitted to the federal IDR process will receive an email notification from auto-reply-federalidrquestions@cms.hhs.gov. The resubmission email notification will contain a unique link to a new form called the Notice of IDR Initiation – Resubmission web form and instructions on the next steps. Initiating parties have four business days from the date of the resubmission email notification to resubmit a dispute after which the resubmission link will no longer work. The departments created a user guide on the new process as a stakeholder resource.

In a separate statement, as a result of a request from payers for additional time, the departments announced an extension of enforcement relief for payers to recalculate qualifying payment amounts (QPAs) in accordance with the Aug. 24, 2023, decision in a Texas Medical Association lawsuit. The departments are allowing payers to continue to use QPAs calculated under flawed methodology outlined in a July 2021 interim final rule that was vacated by the court in August until November 1, 2024. The No Surprises Act frequently asked questions document was updated to reflect this extension.

If you have questions or would like more information, contact Katie Keysor, American College of Radiology® Senior Director, Economics and Health Policy.