CHA has submitted comments on the second interim final rule implementing the No Surprises Act (NSA) that includes provisions related to the independent dispute resolution (IDR) process, good faith estimates for uninsured individuals, and the Patient-Provider Dispute Resolution process.
In the letter, CHA urges the tri-agencies to ensure implementation of the NSA reflects congressional intent by correcting the IDR process included in the second interim final rule, instructing arbiters to consider all of the factors Congress included in the NSA equally — not just to default to a health plan’s median payment rate, the qualifying payment amount (QPA), for a service. .
Additionally, CHA asks the tri-agencies to address the following issues:
- Additional concerns with the IDR process beyond the QPA
- Negotiation initiation process
- Self-pay good faith estimate
- PPDR process
- IDR certification
- Broad enforcement discretion
CHA thanks members for their feedback, which informed comments.