1/ Important #NSA update as @CMSGov has posted "a checklist of reqs. for group health plans" after rec'g @ACEPNow @EDPMA letters & examples detailing numerous instances of #healthplan non-compliance w/ regs; 2/ The agency details several of most impactful non-compliance issues...
2/ health plans requiring that physicians/hospitals proceed through hosted website by the carrier to initiate the req. 30 day open negotiation period + lack of QPA info. + lack of health plan name, address AND email for sending the open negotiation notice 3/CMS states clearly....
3/ that the initial payment should be an amount the health plan "reasonably intends to be payment in full) (p. 2); 4/ CMS makes clear that the "clock" for the 30 day open negotiation period notice begins to run upon sending the notice, not per an "acceptance process or website".
4/ health plans must provide contact information including an email address (emphasis in the original) + that if the plan requires a website that the 30 day clock runs from the date the notice is emailed "regardless whether the non-initiating party "accepts" the notice or not....
5/ Even if the health plan declines 2 accept the 30 open negotiation period notice but the initiating party sent it to a proper email address then the 30 day clock has begun; 6/ details on the QPA which are reiterated from the regs. are also emphasized again. @ASALifeline .....
6/ @RadiologyACR @AmerMedicalAssn @ahahospitals @drdanchoi @sonodoc99 @amychomd @813JAFERD @Valleus556 @ercoderguy @Reese_Tassey @KatieOrrico @SunnyJhaMD @fuzzymittens @mass_marion @MarilynHeineMD @CPakTengMD @RichDuszak @reh3md @NC_ACEP @GAemergency @MAG1849 @MBonilla1
7/ cms.gov/files/document… 2 of the 4 pages below--advocacy can =tiring/frustratingly slow & sometimes appear that the stakeholders are not making progress--this ladies & gentleman is the result in part of #ACEP & #EDPMA members who have worked together weekly for nearly 2 yrs! 
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