• NSA I-Tact

  07.22.24 I-Tact Notes

  Posted by name on July 31, 2024 at 10:40 am

  Quick Recap
  The team discussed the upcoming RCM workshop, antitrust policies, and the potential impacts of incorrect QPA calculations. They also deliberated on current priorities, the challenges of implementing them, and the issue of letter fatigue. Lastly, they explored discrepancies in data, the impact of benchmarking on healthcare costs, and the need for further research to support their positions.

  Patrick will collaborate with Erin to consolidate the draft letter regarding the NSA IDC process rule into one unified document for CMS and other stakeholders.

  Jess will provide data and insights to support the consolidated letter, focusing on the high-level priorities identified in the recent poll.

  Antitrust Policies and Aetna Audit Discussion

  The meeting discusses antitrust policies and a proposed letter to committee leadership regarding the IDR Operations rule. Concerns are raised about plans not complying with the NSA and a draft letter addressing this issue is being prepared. Patrick mentions a web portal for submitting complaints about incorrect usage of CARC and RARC codes. The group also discusses findings from a CMS audit of Aetna’s air ambulance QPAs, with suggestions to send a bipartisan letter to the departments regarding the audit’s implications.

  QPA Calculation, Priorities, and Streamlining Communication

  Patrick, Ed, and Tom discussed the potential impacts of incorrectly calculated QPAs and the delay in enforcement discretion by CMS. They also deliberated on their current priorities and the challenges they face in implementing them, with a focus on protecting patients and ensuring fair payment. The issue of letter fatigue and the need for streamlined communication was also addressed. The team agreed to draft a letter in support of Senator Cassidy’s efforts to rectify issues with the No Surprises Act, aiming to demonstrate to Congress that the departments were not addressing the problems.

  Drafting Letter and Addressing Cooling Issue

  Tom outlined the contents of a letter he was drafting, which included releasing the final operational rule, the need for a ruling on enforceability, and when certain parts of TMA III would be enforced. The team discussed the idea of consolidating the content of several letters into one to avoid “letter fatigue” and to present a more robust request with detailed asks. The team also discussed a new issue regarding the cooling off period, which was causing concern among members. Jess was tasked to look into this issue while on the call.

  ITAC Group Claims and Cooling Off Period Issues

  The team discussed the issues surrounding the cooling off period in the context of ITAC group claims. Paul was tasked with finding out the percentage of ITAC group members affected by this issue. Tom suggested a potential solution to the problem, proposing that during the cooling off period, parties should have to pay whatever the arbitrator decided triggered the cooling off period. However, Patrick pointed out that this solution would likely not be accepted, as it could lead to excessive rates. The team agreed that the best solution would likely come with the finalization of the IDR process rule. In the meantime, Jess was asked to gather data on the issue of perpetual cooling.

  Discrepancy in Data and Brookings Institution Research

  Paul and Ed discussed a discrepancy in two sets of data, while Patrick introduced research conducted by Erin Duffy’s team at the Brookings Institution. The research revealed lower-than-expected rates for emergency medicine in the public use files by the Centers for Medicare and Services. Patrick proposed further research to understand the cause, potentially in collaboration with an external partner funded by the Arnold Foundation. Concerns were raised about the impartiality of the work and the partner’s colleagues, which the partner agreed to share with her team at Brookings.

  QPA, IDR Rates, and Provider Win Rates

  Patrick discusses potential conclusions from the QPA and IDR process rates, including plans under-reimbursing or the rates positively impacting healthcare costs. Ed suggests Greg’s analysis of out-of-network reimbursements could provide insights. Greg shares his analysis showing high provider win rates, far exceeding expected QPA amounts. Ed believes sharing this data could strongly support their position on appropriate reimbursement levels.

  Benchmarking Impact on Healthcare Costs

  The team discussed the impact of benchmarking on healthcare costs and premiums. Andrew Sama, Patrick, and Tom expressed concerns that the data needed to make the cost argument was not available, and the current data suggested that premiums were increasing due to increased administrative costs. Greg highlighted a case where Anthem lost a significant amount of money due to increased administrative fees. Jeff clarified that the Congressional Budget Office (CBO) scores predicted an increase in taxes, not a reduction in premiums. The team agreed to continue gathering data to support their arguments. with suggestions to send a bipartisan letter to the departments regarding the audit’s implications.

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