• NSA I-Tact

  WG Assignments: Proposed Rule

  Posted by name on November 3, 2023 at 11:05 am

  1. Work Group B—IDR and IDRE compliance (Shanna, Chair)
     takes the lead on comments for the proposed rules on batching. We
     have a lot of “in the weeds” expertise in the IDR process in her WG (and
     you know who you are!);

  2. Work Group A—NSA compliance (Bill and Patrick)—takes
     the lead on the proposals to improve transparency prior to IDR.

  3. Work Group C—Legislative and Regulatory—(Tom): The Oct
     6th FAQ states that the Depts. will use “enforcement
     discretion” from now until at least 5/1/24 and possibly 11/1/24 regarding
     the QPA calculations. We have the joint presser from EDPMA, ACEP,
     ASA, ACR and RBMA expressing major concerns about this statement.
     The WG decided to draft a letter to the Depts. outside of the comments to
     request that they re-consider their position. Recall that QPA issues
     cannot be addressed in IDR and CMS has designated itself as the sole
     enforcement mechanism there and now CMS is essentially shirking its
     responsibility to conduct that enforcement.

  name replied 1 year, 5 months ago 1 Member · 0 Replies
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