🧵#OurAMA issues initial summary of “Interim Final Rule (Part 1) Implementing Certain Provisions of the #NoSurprisesAct.”

Several initial concerns:
•Way the QPA (median contracted rate) will be determined
•Provisions that ⬆️ admin burden for physicians without patient benefit Image
2/ July 1 @HHSGov @USDOL @USTreasury (Tri-Agencies), @USOPM released an IFR with comment period tinyurl.com/smenwxk4 implementing many provisions of the #NoSurprisesAct signed into law as part of the Consolidated Appropriations Act, 2021 COVID-19 relief bill.
3/ Given statutory timeframes required under the NSA & the pending implementation of most provisions by January 1, 2022, the Departments made the decision to issue an IFR.

As a result, the requirements outlined in the IFR are final & will become effective on September 13, 2021.
4/ However, the Departments request comments on several aspects of the rule. The AMA will be responding by the September 7, 2021, comment period deadline.

The IFR states that this is the first of several regulations that the Departments will be issuing to implement the #NSA.
5/ Expect to see regulations on:

•IDR process, price comparison tools, certain transparency requirements later this year.

•Insurance card requirements, continuity of care, provider network directions, prohibition on gag clauses) maybe 2022. (To see guidance in interim soon.)
6/ 👉 For a detailed summary by @AmerMedicalAssn of the #NSA IFR (Part 1), please see: tinyurl.com/4ak4b4c9
7/ IFR provides:
• ⬇️ likelihood plans will need to use data from outside, independent databases in determining how QPA is calculated. Done thru broad definitions of “markets,” “geographic regions,” allowing reliance on small data sets, benchmarking for “new service codes,” etc.
8/ IFR provides for:
• ⬇️ role of bonuses, risk sharing, penalties, other incentive-based & retrospective payments or payment adjustments in calc of QPA.

• Process by which a patient receives notice & potentially provides consent for OON care & forgo NSA financial protections
9/ •IFR sets structure for interaction of state & fed surprise billing req’ts as state law preempts fed law when either a set payment amount or dispute resolution process is in place for state-regulated plans &, when applicable, self-funded ERISA plans that opt-in to state law.

• Sets facilities/physicians/providers criteria to provide required disclosure to patients about state & federal balance billing protections.
• Broadens complaint processes for patients, physicians, plans.
• Reaffirms several patient protections for EM care, e.g. PLP.
11/ AMA has several initial concerns about the way QPA will be determined.

& while the Dep’ts attempt to consolidate/standardize some administrative requirements on physicians, in other areas they ⬆️ them in ways that may not benefit patients but result in burdens on physicians.
12/ The @AmerMedicalAssn will provide detailed comments to the Departments upon a full analysis of the Interim Final Rule (Part 1) Implementing Certain Provisions of the No Surprises Act. Stay tuned.

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More from @MarilynHeineMD

21 Jul
🧵AMA to #Congress:

•Do not extend 2% #Medicare sequester as a spending offset in soon-to-be considered #infrastructure package.

•Do not divert scarce health-related offsets to meet objectives unrelated to healthcare.

Physicians already face steep Medicare fiscal challenges.
2/ AMA expresses “deepening alarm concerning the growing financial instability of the Medicare physician payment system.”

“Not only does Congress seem indifferent to the confluence of fiscal uncertainties confronting physician practices at the end of this year, but…”
3/ “…lawmakers’ pursuit of policies to extend the current Medicare sequester that, in effect, will require physicians and health systems to pay for
hard infrastructure amplifies our ongoing concerns.”
Read 21 tweets
19 May
1/ @AmerMedicalAssn⁩ press release on the urgency to #fixpriorauth:

At the height of the #COVID19 #pandemic, physicians reported being bedeviled by unnecessary, bureaucratic obstacles that the health insurance industry pledged to reduce three years ago.
2/ The data highlights the urgent need for new bipartisan legislation introduced in the House, the Improving Seniors’ Timely Access to Care Act. [TY @RepDelBene @MikeKellyPA @RepBera @RepLarryBucshon for introducing this vital measure.]

[See data here: ama-assn.org/system/files/2…]
3/#OurAMA-conducted survey shows physicians are running into roadblocks because of #priorauthorization, the process of requiring health care professionals to obtain advance approval from health plans before a prescription medication or medical service is delivered to the patient.
Read 18 tweets
17 May
1/ New report from ⁦@AmerMedicalAssn⁩ provides:

•Detailed look at official US healthcare spending estimates through 2019 using data from ⁦@CMSGov
•Preliminary estimates of 2020 health spending from ⁦@Altarum

2/ •Health spending was 17.7% of GDP in 2019 and increased by 4.6% to $3.8 trillion ($11,582 per capita).
•Spending in hospital care (6.2%) and prescription drugs (5.7%) grew faster than physician services (4.2%) in 2019.
3/ • In 2019, spending growth in #Medicare (6.7%) and out-of-pocket payments (4.6%) reached their highest rates in the last decade while private #healthinsurance (3.7%) and #Medicaid (2.9%) were on a downswing.
Read 5 tweets
10 Apr
1/ 👉 “After careful consideration and given the significant concerns set forth...⁦@AmerMedicalAssn⁩ respectfully urges the @TheJusticeDept to conduct a thorough examination of the antitrust ramifications of UHG/Optum’s proposed acquisition of CHNG.” tinyurl.com/e2nfztbr
2/ @AmerMedicalAssn writes:

“There is substantial overlap in markets for health information technology (IT)/analytics services that the merging firms supply to health insurers, physicians, and hospitals.”
3/ “Given this overlap and the companies’ large sizes, it is likely that the merging firms have been, or absent the merger would become, substantial head-to-head competitors.”
Read 16 tweets
17 Mar
1/ @AmerMedicalAssn⁩ strongly supports HR1868 to protect physician practices: tinyurl.com/tna2a8hk

Prevent across-the-board direct spending cuts that threaten financial viability of physician practices, especially during #COVID19 PHE & beyond. @SpeakerPelosi @GOPLeader
2/ HR1868 is vital to protect physician practices:

•Extend current moratorium on the 2% Medicare sequester cuts past the 3/31/21 deadline

•Avoid additional Medicare statutory PAYGO cut of up to 4% triggered by budgetary impact projected under American Rescue Plan Act of 2021
3/ The #COVID19 #pandemic persists and continues to have a substantial fiscal impact on physician practices.

It is critically important that physicians are able to provide frontline care to #Medicare beneficiaries.
Read 12 tweets
15 Mar
1/ Take care to not run afoul of #HIPAA. Lest you risk penalties and jeopardize the patient-physician relationship.

“Protecting information gathered in association with the care of the patient is a core value in health care.” tinyurl.com/45rk8hr4 ama-assn.org/practice-manag…
2/ The Code of Medical #Ethics also states, “However, respecting patient #privacy in other forms is also fundamental, as an expression of respect for patient autonomy and a prerequisite for trust.”
3/ Physicians and hospitals may share patient information without explicit patient consent for treatment, payment, business operations.

@HHSOCR enforces #HIPAA. Voluntary compliance and corrective action without a fine is a goal, but penalties are steep for “willful neglect.”
Read 8 tweets

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