For providers offering items and services to out-of-network (OON) patients in certain emergency and nonemergency settings, the No Surprises Act (NSA) establishes a new federal independent dispute resolution (IDR) process designed to resolve applicable payment disputes relating to these OON items and services. A second interim final rule (the IDR Rule) published by the departments of the Treasury, Labor, and Health and Human Services (the Departments) on 7 October 2021 established the specific mechanics of this federal IDR process (IDR Process). We previously published an alert summarizing the IDR Process, available here.1 Since the publication of the IDR Rule, the Departments have issued further guidance relating to the IDR Process, including a December 2021 Guidance Document for Certified IDR Entities.2
As of 1 January 2022, the IDR Process is now in effect. Accordingly, providers offering applicable items and services will need to quickly familiarize themselves with the mechanics and intricacies of navigating the IDR Process. This preparation should including getting comfortable with the IDR Process’s procedural formalities, its rapid timeline, and the scope (and limitation) of discretion available to IDR Process arbitrators (such as the mandated presumption that the qualifying payment amount (QPA) should apply and how a party can rebut that presumption). This alert summarizes eight potential traps within the IDR Process that could frustrate a provider...
As Nigeria prepares for the 2027 general elections, political campaigns and online discussions are expected to intensify across social media and messaging platforms. Alongside legitimate political...