Federal Departments Publish No Surprises Act IDR Process Update

On April 27, 2023 the Federal Departments responsible for the implementation of the No Surprises Act published a status update on the Federal Independent Dispute Resolution (IDR) Process for the period from April 15, 2022 through March 31, 2023. The update summarizes the findings in the “Initial Report on the IDR Process” April 15-September 30, 2022 and the release of the most recent report “Partial Report on the IDR Process”, October 1 – December 31, 2022.

Status Update Findings:

Dispute Volume has greatly exceeded the Departments annual projection citing the caseload as “nearly fourteen time greater than …initially estimated”. The stats for the period April 15, 2022 – March 31, 2023, are as follows:

  • 334,828 disputes initiated through the Federal IDR portal
  • 122,781 disputes challenged, by non-initiating parties, as ineligible for Federal IDR process
  • 39,890 of the 106,615*disputes closed during this period were determined ineligible for the Federal IDR process
  • 42,158 payment determinations rendered by Certified IDR Entities
  • 71% of the 42,158 IDR payment determinations rendered were awarded to the initiating party

*Total closed case count includes cases for which payment determination was rendered, ineligible cases, submissions where the disputing parties withdraw or reach an outside settlement and cases for which fees were unpaid.

Fourth Quarter Report Highlights and Comparisons to Q3 2022:

  • 110,034 disputes initiated through the Federal IDR portal, representing a 53% increase over Q3 2022
  • 103,170 of the disputes initiated were for emergency or non-emergency items and services
  • 300% increase in IDR payment determinations Q4 versus Q3 (12,662 compared to 3,248 representing 40% of closed disputes versus 15% respectively)
  • 30% of closed disputes determined ineligible for the Federal IDR process compared to 69% in Q3 (9,525 disputes determined ineligible compared to 14,164 in Q3)
  • 9,226 disputes initiated in New York and New Jersey (5,395 and 3,831 respectively) representing 8% of the total disputes initiated
  • $6.6 million in Federal Expenditures to administer the IDR process
  • $637,350 total administrative fees collected by HHS for all disputes

While the volume of disputes has continued to increase Q4 versus Q3, the process is improving related to ineligible cases and the number of disputes being processed.  CH Revenue Management Solutions has successfully processed thousands of claims on behalf of our nationwide  clients.  With an easy-to-use HIPAA compliant portal, clients are able to simply upload claims for proper and timely handling allowing them to focus on what they do best — the practice of medicine and caring for patients.  We remain vigilant in pursuing fair payments for out-of-network providers leveraging our expertise, among other factors, in commercial insurance and NSA regulations. 

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