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Comment Letter | Payment Reimbursement and Managed Care

HFMA Comments on Requirements Related to Surprise Billing, Part II Interim Final Rule

Comment Letter | Payment Reimbursement and Managed Care

HFMA Comments on Requirements Related to Surprise Billing, Part II Interim Final Rule

HFMA  submitted comments to CMS on the Interim Final Rule with comment period implementing certain provisions of the No Surprises Act; Part II issued by the Department of Health and Human Services, the Department of the Treasury, the Department of Labor, and the Office of Personnel Management on October 7, 2021. The letter includes comments on specific proposals related to:

  • Provider/health plan negotiation process
  • Evaluation criteria for independent dispute resolution (IDR) entities
  • The anchoring benchmark of the IDR process is the qualifying payment amount (QPA) the health plan presents to arbitration
  • Good faith estimates for uninsured/self-pay patients
  • Uninsured/self-pay patient-provider dispute resolution threshold

Download the comment letter

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