The organization recommended CMS update the independent dispute resolution portal to improve communication between disputing parties and adjust the form field requirements.
The Medical Group Management Association (MGMA) has asked CMS to update the federal independent dispute resolution (IDR) portal to streamline the arbitration process for determining an out-of-network payment rate for a surprise medical bill.
CMS launched the online portal in April 2022 to create a space where healthcare providers and payers can initiate the IDR process within four days after the 30-day negotiation period.
In a letter to CMS Administrator Chiquita Brooks-LaSure, MGMA offered several recommendations to help healthcare practices complete the IDR initiation while simultaneously managing staffing shortages, administrative costs, and policy changes.
First, the organization requested communication updates to the portal. Using the current portal, practices cannot communicate directly with the other disputing party or IDR entity. MGMA asked CMS to update the platform to allow all parties involved in a dispute resolution case to communicate via the platform during the process.
“Ongoing, open communication among all involved parties is critical to ensure a transparent dispute resolution process,” the letter stated. “Currently, practices must download the submitted IDR claim and email the documentation to the non-initiating party. This creates additional burdens and the potential for missed communication.”
Providers and plans must maintain and update contact lists to ensure disputing parties receive communication. Parties also must have systems in place to track different dispute claims.
Seamless communication would allow all parties to stay aware of the timeline and deadlines to avoid any confusion, MGMA said. An updated communication platform would also reduce the administrative burden for larger practices with high volumes of claims and smaller practices that lack staff and resources to track claims manually.
Next, MGMA asked CMS for an option to edit existing applications on the portal before submitting them. Parties should be able to save an IDR application and return to the form later to make any changes necessary.
In addition, the portal should auto-populate any redundant information throughout the IDR initiation, such as dates and contact information. This would help streamline the submission process and reduce the time that staff members spend re-entering information, according to MGMA.
MGMA also requested that CMS develop a function that allows practices to edit previously saved line items within a dispute claim, view what line items have already been entered and saved, and delete any unneeded claims.
Third, the letter recommended that CMS adjust the information it requires parties to provide during an IDR process. MGMA asked for a new field that allows providers and health plans to communicate what specific beneficiary services are being disputed under a given single claim for a batched dispute to reduce confusion among disputing parties.
MGMA also noted that the form field for the qualifying payment amount (QPA) should be optional for providers.
“As health plans are calculating the specific QPA, MGMA believes plans should be held responsible for ensuring this critical information in the negotiation process is appropriately communicated to all involved parties,” the letter read. “Additionally, MGMA recommends CMS provide additional clarity about what documentation about the QPA should be provided and is sufficient to support the dispute resolution process.”
The organization requested that the form field for health plan type be optional for providers as well. Under the current IDR initiation process, providers must indicate whether the involved health plan is a group health plan, health insurance issuer, or a Federal Employees Health Benefit program, but practices do not always have that information on hand, MGMA noted.
Finally, MGMA recommended a few minor updates to the IDR portal. CMS should create a timeline that lays out the different deadlines for the IDR process and link the timeline to all surprise billing materials and allow practices to submit batched claims under a single dispute to expedite the process.
The agency should also provide continuing educational support and best practices for providers and health plans on how to submit claims through the IDR portal, the letter concluded.
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