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Premier submitted comments to the administration on the Surprise Billing Part 2 interim final rule (IFR). The IFR implements the consumer protections and dispute resolution process for out-of-network payment amounts as required by the Consolidated Appropriations Act of 2021.
The IFR establishes the federal independent dispute resolution (IDR) process that out-of-network providers, facilities, providers, plans, and issuers may use to determine the out-of-network rates in the event that an agreement cannot be reached in open negotiation. The IFR also establishes a patient-provider dispute resolution process for uninsured or self-pay patients. While Premier generally supports the provisions of the IFR, there are several key areas where the Departments could improve the regulations and their implementation: