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What is the first step in the IDR process under the No Surprises Act?
Claim Submission - The process begins with the submission of out-of-network surprise claims by either the payer or the provider.
What does CMS do after a claim is submitted in the IDR process?
Initial Review by CMS - CMS reviews the claim to determine its eligibility for the IDR process.
What happens if there is a disagreement over a claim in the IDR process?
Dispute Initiation - If there is a dispute over the claim, either the payer or the provider can initiate the dispute resolution process.
What is the purpose of the negotiation period in the IDR process?
Negotiation Period - An open negotiation period allows both parties to attempt to resolve the dispute.
What happens if negotiations fail in the IDR process?
IDR Submission - If negotiations fail, the dispute is submitted to the IDR process for further resolution. The IDR process involves a neutral third party reviewing the dispute to make a final decision.
Who handles the case after it is submitted to the IDR process?
IDR Entity Assignment - An independent dispute resolution entity is assigned to handle the case.
What do parties do during the information exchange step in the IDR process?
Information Exchange - Both parties exchange necessary information through the IDR portal.
What is the role of the IDR entity in the decision-making step?
Decision Making - The IDR entity reviews the information and makes a decision on the dispute.
How is the payment amount determined in the IDR process?
Payment Determination - The payment amount is determined based on the IDR entity's decision.
How are parties informed of the resolution in the IDR process?
Resolution Notification - Both parties are notified of the resolution.
What must parties do after receiving the resolution in the IDR process?
Compliance and Reporting - Compliance with the IDR decision is required, and the outcome is reported.
What are the key requirements for the new IDR registry?
Enhanced IDR portal management, increased notices and communications, specific information for registration including legal business name, coverage type, state laws, contact information, and more.
What are the key timelines for registration in the IDR process?
Register within 30 business days after the final rule's effective date, updates within 30 business days of changes, and annual confirmation during Q4.
What are the compliance considerations in the IDR process?
Updating information within 30 days of changes, confirming accuracy annually, and third parties can assist with registration but plans and issuers retain compliance responsibility.
What are the main communication problems addressed by the proposed regulations?
Difficulty finding contact information, determining applicable laws, and differentiating between multiple plans; issues with initiating negotiations with incorrect information or the wrong plan/issuer.