Manatt litigation Partner Harvey Rochman was quoted extensively in RevCycleIntelligence on the No Surprises Act (NSA) final interim rule regarding medical billing and its potential impact on revenue cycle workflows. The publication noted that revenue cycle leaders should particularly pay attention to the part of the IFC that prohibits balance billing. “In the rule, HHS emphasizes the need for hospitals and other providers to be proactive in ensuring that they do not violate balance billing protections,” Rochman explained. “Under the NSA, hospitals may be subject to civil monetary penalties of up to $10,000 per violation. However, the HHS Secretary will waive those penalties if the hospital (i) does ‘not knowingly violate’ the law, (ii) ‘should not have reasonably known it violated’ the law and (iii) within 30 days withdraw the any improper portion of the bill and make restitution with interest of amounts improperly charged.”
Rochman was also quoted extensively in HealthLeaders on the five details revenue cycle leaders need to know about the final interim rule and what is needed to comply with the Act. The publication reported that the recently released =interim final rule outlines certain requirements of the NSA, which is designed to protect patients from surprise medical bills and balance billing. “Revenue cycle leaders need to be highly focused on NSA implementation, which will have major impacts on hospital operations and will require many new processes and strategies to be implemented in the next six months,” Rochman said. He added: “This will require a huge effort and substantial resources and will have impacts on revenue that are not yet known.”
Additionally, Rochman noted that the interim final rule provides revenue cycle leaders with important compliance information, including how the plans must calculate the Qualifying Payment Amount (QPA). “The QPA is the median contracted rate paid by the patient’s plan in 2019 for the item or service in the applicable geographic region (increased for inflation),” Rochman explained. “Revenue cycle leaders will want to fully understand how the QPA is calculated so they can evaluate plan calculations and establish processes to maximize revenue.”
Rochman’s full comments in RevCycleIntelligence are available here.
Read the full HealthLeaders article here.