Latest / Becker’s Healthcare Podcast / The Next Phase of Federal Independent Dispute Resolution: What RCM Leaders Should Be Building Now
Transcript
- 0:00- Hello, everyone. This is Erica Spicer Mason with
- 0:02- Becker's Healthcare. Thank you so much for tuning
- 0:05- in to the Becker's Healthcare podcast series.
- 0:08- Today, we're going to talk about the next
- 0:09- phase of federal independent dispute resolution
- 0:13- and what RCM leaders should be building right
- 0:15- now. So joining me for this conversation, we
- 0:18- have two leaders from Aspirion.
- 0:20- We have Chase McGrath, the vice president of
- 0:23- product, and Nikki Richson, the senior director of
- 0:26- payment variance.
- 0:27- Chase, Nikki, so thrilled to have you with
- 0:30- us today.
- 0:31- To get us kicked off here, would you
- 0:33- both take just a moment to introduce yourselves
- 0:35- and tell us a little bit about your
- 0:37- background?
- 0:38- Chase, would you like to get us started?
- 0:40- Yeah. Happy to. So my name is Chase.
- 0:43- As mentioned, I lead product development. And, really,
- 0:46- my day to day is just involved in
- 0:48- trying to figure out
- 0:49- what are the business problems out there, what
- 0:51- are my RCM operational leaders trying to grapple
- 0:54- with, and how can technology
- 0:56- solve those problems, and then bring that through
- 0:58- to fruition.
- 1:00- Fantastic. Great to have you with us, Chase.
- 1:02- Thank you. And Nikki, tell us a little
- 1:04- bit about you. Hi, everyone. I'm Nikki Richson,
- 1:07- senior director of Payment Variance.
- 1:09- I've been in the revenue cycle space for
- 1:11- over ten years and have worked directly within
- 1:14- the No Surprises Act since it first took
- 1:16- effect in 2022.
- 1:18- It's been an evolving process from those early
- 1:21- days to where we are today, so I'm
- 1:22- excited to talk about what we've learned along
- 1:24- the way and what's changed and where I
- 1:26- think we're headed next.
- 1:28- Yeah. Nikki, thank you so much. And, you
- 1:30- know, you really got us started there on
- 1:32- the note that I was hoping we could
- 1:34- open up on, which is
- 1:36- really grounding our listeners in the No Surprises
- 1:39- Act. As you mentioned, it took effect
- 1:42- several years ago in 2022.
- 1:44- And
- 1:45- as you,
- 1:46- hinted into that, it's there have been some
- 1:48- changes since. So I'd love to hear from
- 1:51- you on what has changed the most for
- 1:54- providers between those early days of federal IDR,
- 1:57- and what did the industry learn the hard
- 2:00- way across those changes?
- 2:02- Mhmm. Thanks, Erica. We have come a long
- 2:05- way in the past several years,
- 2:07- and still growing and evolving every day. Never
- 2:09- a dull moment in in this space or
- 2:11- really health care in general.
- 2:14- A few, you know, key things that have
- 2:17- we've really learned in the last couple of
- 2:18- years. So first, when it comes to IVR
- 2:21- eligibility,
- 2:22- knowing the difference between state and federal,
- 2:26- really has to be determined before
- 2:28- submission
- 2:29- not after.
- 2:30- We also have learned that deadlines are
- 2:34- completely unforgiving, so we really have to monitor
- 2:37- and track those,
- 2:38- with a 100% accuracy.
- 2:41- We know that the QPA, the qualifying payment
- 2:44- amount is important
- 2:46- but the case cannot start and stop with
- 2:48- the QPA, there's other factors that need to
- 2:50- be considered.
- 2:52- We know that templates can help you scale
- 2:54- but
- 2:55- blind templating can really hurt you.
- 2:58- We know that, you know, providers,
- 3:01- typically cannot manage the federal IDR
- 3:04- or the IDR process in general exclusively
- 3:07- inside a traditional EHR or patient account work
- 3:10- queue.
- 3:11- And the one of the biggest things,
- 3:14- that we're all still learning and and,
- 3:16- dealing with today is that winning
- 3:19- the determination is not the end of the
- 3:21- process.
- 3:22- Nikki, it's pretty remarkable
- 3:25- what you just listed off there. You know,
- 3:26- we're we're talking from everything
- 3:28- from that basic knowledge of
- 3:30- knowing whether it's a state or a federal
- 3:33- matter,
- 3:34- deadlines being unforgiving.
- 3:37- So appreciate you kind of setting the scene
- 3:39- on what providers are facing in this realm.
- 3:43- And I know in line with some of
- 3:44- these changes that we've hinted at already, we've
- 3:47- seen that CMS has released the federal IDR
- 3:49- operations final rule back in May of this
- 3:52- year.
- 3:53- So I'd love to hear from both of
- 3:54- you on this. What stands out to you
- 3:56- as the most consequential
- 3:58- change in that latest May update for providers?
- 4:02- Absolutely. I'll kick us off here. So I
- 4:04- think that one of the most consequential
- 4:06- is the federal IDR gateway portal.
- 4:10- This will be a one stop hub for
- 4:12- federally
- 4:13- eligible negotiations
- 4:14- and IDR submissions.
- 4:16- The process visibility and streamline capabilities
- 4:19- paired with improved tracking will greatly improve
- 4:23- the current process and
- 4:25- be incredibly helpful for everyone in this space.
- 4:28- Super helpful for you to raise up the
- 4:30- portal, Nikki, and Chase. Is there anything else
- 4:32- that you would add here?
- 4:34- Yeah. I actually think there's a few things
- 4:36- that are pretty interesting,
- 4:37- coming out of those changes,
- 4:39- pending the final rule change.
- 4:42- So the fee structure, the batching, and then
- 4:44- that reviewer entity selection, I think, really
- 4:47- enable parties to pursue more cases with the
- 4:50- health technology,
- 4:51- much more so than in the past. And
- 4:53- then that standardization
- 4:55- of, remittance codes, so requiring that payers use
- 4:58- standard codes similar to what we kinda see
- 5:01- in the denial space, That also addresses, I
- 5:03- think, a pretty major triage issue that we
- 5:05- saw in the workflow where even trying to
- 5:07- find these cases when they come in to
- 5:09- understand what's eligible for the process was was
- 5:11- pretty difficult. So that allows, I think, across
- 5:14- the spectrum,
- 5:16- quite a bit of standardization,
- 5:18- automation to be put in place, and to
- 5:20- allow things to kind of flow on more
- 5:22- of a technology
- 5:24- sort of conveyor belt throughout the entire process.
- 5:27- And we also believe that just with proper
- 5:29- analytics in place,
- 5:30- this all opens up the opportunity for
- 5:33- better case prioritization,
- 5:35- submission matching, and then entity routing to basically
- 5:39- optimize the process down the road based on
- 5:41- what we see working with those initial submissions
- 5:44- once the changes are live and and being
- 5:46- able to really learn from those.
- 5:48- Yeah. Chase, I appreciate
- 5:50- what you've just touched on because I think
- 5:53- if I'm picking up what you're saying, it
- 5:54- it sounds like these changes have really put
- 5:57- to the forefront that technology infrastructure
- 6:00- needs to be able to adapt,
- 6:02- to really uphold some of these
- 6:04- latest changes and rules.
- 6:06- And before we get deeper into that, Nikki,
- 6:09- I wanted to go back to you just
- 6:10- for a moment here. I know you mentioned
- 6:12- the the federal IDR gateway portal. Since this
- 6:14- is something newer, would you mind sharing just
- 6:16- a little bit more about that portal with
- 6:18- our listeners who this may be news to
- 6:20- them?
- 6:22- Yes. Absolutely.
- 6:23- So currently,
- 6:25- when working with
- 6:27- federally eligible IDR submissions, you know, the process
- 6:31- is a little clunky
- 6:32- in sorts where,
- 6:34- you are typically emailing off to
- 6:38- a distribution box on the the payer side.
- 6:40- We're, you know, working,
- 6:42- with CMS and submitting
- 6:45- forms and submissions through there.
- 6:47- So you have a lot of pieces of
- 6:50- the process puzzle that are broken up, and
- 6:52- this portal is really going to tie it
- 6:54- in nicely together. I think this is also
- 6:56- very helpful for any organizations that are using
- 7:00- vendors in this space.
- 7:02- This portal is going to be, like I
- 7:04- had mentioned that one stop, you know, shop
- 7:06- that hub
- 7:08- where
- 7:09- federally eligible negotiations
- 7:11- will start
- 7:12- in this portal. Everyone will have visibility that
- 7:15- has access,
- 7:16- whether it's a vendor, another third party,
- 7:19- the organizations,
- 7:20- CMS as well, and it gives everyone the
- 7:23- ability to track, monitor.
- 7:26- You can look at reporting capabilities
- 7:29- for what's winning and what's losing, any additional
- 7:31- trends,
- 7:33- any issues that are are
- 7:35- taking place. And then you have that next
- 7:37- step of those federally eligible,
- 7:40- claims of the negotiation period,
- 7:43- ends. Unfortunately, a resolution was not able to
- 7:46- be met, so therefore, throughout the same portal,
- 7:49- you can then move into
- 7:51- the IDR
- 7:52- process. The IDR entities will be,
- 7:55- in this portal as well. So, of course,
- 7:58- streamlined, you know, communication and identification
- 8:01- there.
- 8:02- And it all just stays in one
- 8:04- one hub that will make things a lot
- 8:06- easier for everyone and and less less contact
- 8:09- confusion,
- 8:10- which I think will be incredibly helpful. And
- 8:12- again, just the overall visibility will really help
- 8:15- connect
- 8:16- all, players in this space.
- 8:19- Mhmm.
- 8:20- Yeah. Nikki, thanks so much for
- 8:22- clarifying that. Really helpful to know.
- 8:25- And I know that, Nikki, both you and
- 8:28- Chase have have touched on this idea that
- 8:31- federal IDR and then the processes that it
- 8:34- entails do not necessarily
- 8:36- fit neatly into traditional,
- 8:39- technology infrastructure like the EHR or revenue cycle
- 8:42- workflows.
- 8:44- So I'd like to hear from you both
- 8:46- on where this work
- 8:48- lives inside of a provider organization, and and
- 8:51- what are you seeing breakdown when teams try
- 8:53- to manage it with their existing tools and
- 8:56- processes?
- 8:57- Mhmm.
- 8:58- Absolutely.
- 8:59- You know, today, we see that for many
- 9:01- organizations,
- 9:02- it still lives in those traditional,
- 9:05- work queues and EHRs
- 9:08- right alongside
- 9:09- normal, you know, claims follow-up,
- 9:12- and account resolution work.
- 9:14- We also see organizations
- 9:16- that are continuing
- 9:18- to,
- 9:19- try to adapt to better identifying and managing
- 9:21- this process.
- 9:23- However, that has meant that these claims and
- 9:26- accounts are living on spreadsheets.
- 9:29- So those spreadsheets and in those traditional work
- 9:32- queues, you know, that relies really heavily on
- 9:35- manual entry, and it does require a 100%
- 9:38- accuracy
- 9:39- to ensure that everything is identified correctly,
- 9:42- deadlines aren't missed, fees
- 9:45- are paid timely.
- 9:46- So there's a lot of of room for
- 9:49- error in in the current traditional spaces.
- 9:52- And, Nikki, thanks for for shedding some light
- 9:55- on where you're seeing this process
- 9:57- hit its limitations at at organizations.
- 9:59- Chase, how does this compare to what you're
- 10:01- seeing on the ground?
- 10:03- Yeah. So like Nikki mentioned, you know,
- 10:05- spreadsheets seem to be the order of the
- 10:07- day at a lot of organizations. And and,
- 10:09- really, that's because
- 10:11- EHRs don't really support this type of a
- 10:14- life cycle. They're really built around,
- 10:17- obviously, the clinical workflows and then traditional RCM
- 10:20- workflows, but they're not really built to manage
- 10:22- dispute life cycles.
- 10:24- So we getting into this space, there was
- 10:26- really a need to create that structure
- 10:28- and build sort of our own version of
- 10:30- this workflow platforming
- 10:31- that was designed around that dispute life cycle.
- 10:34- We didn't really see anything in the market
- 10:36- to address this, And so kind of having
- 10:38- that custom built technology
- 10:40- that's designed to manage the deliverables, the deadlines,
- 10:43- the sort of key steps, as well as
- 10:46- those really tight timelines that we see in
- 10:47- the IDR process
- 10:49- What was sort of an imperative to be
- 10:51- a credible player in this space.
- 10:53- And, you know, with the technology in place,
- 10:55- we now have process discipline
- 10:57- at scale that ensures quality and consistency of
- 11:00- submissions,
- 11:01- and then making sure that you meet all
- 11:02- those requirements and deadlines,
- 11:05- and then, of course, still leveraging human experts
- 11:07- for review of outputs and kind of final
- 11:09- approval on those packages
- 11:10- before they go out for submission.
- 11:12- So, certainly, it's a challenge we saw.
- 11:15- We know a lot of other organizations are
- 11:16- trying to figure out what's the best way
- 11:18- to manage this, and I'm sure seeing that,
- 11:20- hey, hey. My traditional EHR, EMR just really
- 11:23- isn't up to the task because it's it's
- 11:25- really designed to solve a different problem.
- 11:28- Absolutely. I mean, everything that you both have
- 11:30- described already,
- 11:32- the word dynamic comes to mind whether we're
- 11:34- talking about federal IDR
- 11:36- itself and and the changes that we see
- 11:38- on a regular basis, but then down to
- 11:40- the requirements that you're speaking to, meeting deadlines,
- 11:43- ensuring submissions have full documentation and are compliant.
- 11:48- It it's a lot for
- 11:50- any one system to handle. So,
- 11:52- Chase, I'll stick with you for this next
- 11:54- question.
- 11:55- As we see federal IDR continuing to change,
- 11:59- what specific capabilities do you think providers should
- 12:01- look for in a technology or a services
- 12:04- partner to ensure that they're staying compliant without
- 12:07- constantly rebuilding their workflows?
- 12:10- Yeah. And as you said, right, the keyword
- 12:12- is dynamic, and things are dynamic in this
- 12:16- space. We've seen changes this year.
- 12:18- We anticipate things will evolve over time as,
- 12:21- you know, the regulators learn and get feedback
- 12:24- from the industry. So I think the the
- 12:26- key things to keep in mind are that
- 12:28- the systems have to be configured to ensure
- 12:30- compliance at scale. So that way, you know
- 12:32- you're following the process
- 12:33- consistently each and every time, and then also
- 12:36- updating rules and logic and and sort of
- 12:39- business process orchestration
- 12:41- as needed when those things change, when regulatory
- 12:44- requirements evolve, your business needs change,
- 12:47- so it's sort of keeping pace. So I
- 12:50- would say a strong partner will have a
- 12:51- product leader or really a product function that's
- 12:54- working with those customers directly
- 12:56- to just ensure that platforms and workflows are
- 12:59- staying up to date with those changes. And
- 13:01- when you work with a partner, you know,
- 13:02- you should have the expectation that they're the
- 13:04- ones staying on top of industry changes.
- 13:06- They're the ones taking a proactive approach to
- 13:08- compliance, and and they're really sort of putting
- 13:10- you at ease and ensuring that as your
- 13:13- partner, you know, you're already ahead of the
- 13:15- game. Right? That that's really what you're paying
- 13:16- for.
- 13:18- Yeah. Chase, I I appreciate how you outlined
- 13:20- those capabilities so clearly, and it it definitely
- 13:25- I I can see how this would warrant
- 13:26- additional support from a partner,
- 13:28- just to simply navigate the complexity that comes
- 13:31- along with federal IDR.
- 13:33- It's been a great conversation
- 13:35- with you both today. I know we've covered
- 13:37- a lot of ground in a short time,
- 13:39- but I'm curious if there's anything else that
- 13:42- we haven't covered that you think our listeners
- 13:44- should walk away with or even any final
- 13:47- thoughts that you'd like to,
- 13:50- that you'd like to leave them with. So
- 13:51- I'll open up the floor to you both
- 13:53- for those final takeaways.
- 13:55- Thank you so much, Erica, for meeting with
- 13:58- us today and and going over these topics.
- 14:00- I do have a couple of things that
- 14:02- I think are really important,
- 14:04- some key dates
- 14:05- coming up that providers should be aware of.
- 14:08- First is September 15
- 14:10- is the phase one of the federal IDR
- 14:13- portals
- 14:14- release starting with the administrator
- 14:17- level account creation.
- 14:19- The portal itself is supposed to launch before
- 14:21- the end of this year, 2026.
- 14:23- So phase one administrator
- 14:26- account creation, September 20 or sorry, September 15.
- 14:30- Also, effective January 1, there are nine new
- 14:33- NSA
- 14:35- related RAR codes.
- 14:36- Those codes have already been released.
- 14:39- CMS did a press release on them so
- 14:41- you can find more information.
- 14:43- But we do urge organizations to begin building
- 14:46- and updating their current NSA identification
- 14:49- processes now to get ahead of the January
- 14:52- 1,
- 14:53- implementation.
- 14:55- Nikki, thank you so much for highlighting those
- 14:57- key dates for our listeners.
- 14:59- Chase, eager to hear your final thoughts here
- 15:02- too.
- 15:03- Yeah.
- 15:04- Thanks to you both, for, you know, the
- 15:06- input from Nikki and then just for having
- 15:07- us here for this conversation. So
- 15:10- I think I would just finish this out
- 15:11- by saying, as Nicky pointed out, these changes
- 15:14- are coming really soon. So I would either
- 15:16- start engaging those internal technology and product partners
- 15:19- to be ready,
- 15:21- as these things come to fruition or look
- 15:23- for a vendor immediately because,
- 15:26- time is definitely running out.
- 15:28- Yeah. Time is at the essence.
- 15:30- Well, thank you both so much again for
- 15:32- everything that you shared with our listeners today.
- 15:35- A lot of really grounded
- 15:38- advice and reminders here in this conversation.
- 15:40- So, again, thanks so much for making the
- 15:43- time to join Becker's today. Thanks, Erica.
- 15:46- Thank you.
- 15:47- And, of course, we'd also like to thank
- 15:49- our sponsor for today's session, Aspirion.
- 15:52- Listeners, be sure to tune in to more
- 15:54- podcasts from Becker's by visiting our podcast page
- 15:57- at beckershospitalreview.com.