Robert Chavez, MD
President, IEPC
Providence Little Company of Mary Medical Center Torrance

Hello friends and colleagues,

For those of you engaged in the No Surprises Act IDR process, there is a recent bit of good news you may want to alert your revenue cycle management company about. This is regarding your past out of network claims previously ineligible for IDR due to deadlines to submit IDR claims. Due to widespread non-compliance by payors who failed to include required information on EOBs and remittance advisories, specifically details mandated by CMS under the No Surprises Act (NSA), there is now a pathway to submit eligible claims from 2022 forward.

This is important because CMS guidance expects payors to include specific IDR-related data in payment determinations. However, many payors failed to do so. As a result, this may extend your eligibility window for initiating IDR on older claims. If you or your revenue cycle management company didn’t file claims or missed IDR deadlines due to missing or incorrect information from a payor, those claims may now be reviewed. If you think you may have eligible claims, alert your team member or RCM company who manages IDR process as soon as possible to see if any of your claims qualify. This is a narrow window and is expected to close once CMS and payors tighten enforcement.