Ghost Rates and $15 Disputes
Jeffrey discusses ghost rates, QPA calculations, the economics of federal IDR, unpaid awards, spine-surgery reimbursement, and state and federal dispute processes.
Insights
Healthcare reimbursement insights for providers.
Analysis of No Surprises Act arbitration, payer conduct, reimbursement policy, and the practical decisions that shape provider recovery.
Podcast appearances
Jeffrey Halkovich on CLAIMED
Two practical conversations about out-of-network reimbursement, the No Surprises Act, QPA methodology, federal IDR, and what happens after an award is issued.
OON Anesthesia & the No Surprises Act
Jeffrey explains claim eligibility, QPA-based initial payments, open negotiation, IDR documentation, and the administrative mistakes that can cost providers recovery opportunities.
Latest analysis
Provider-side perspective on reimbursement developments.
Two Federal IDR Entities Denied Recertification: What Providers Should Know
Federal regulators denied recertification to IPRO and Network Medical Review Company. Halkovich Law explains the immediate effect on new and open disputes and why a win rate alone cannot establish an entity's performance.
Read the Halkovich Law commentaryWhen an Insurer Does Not Pay a Federal IDR Award
The New York Times reports that some plans are withholding payments after providers prevail in federal IDR. Halkovich Law explains the 30-day payment rule, enforcement gap, and records providers should preserve.
Read the Halkovich Law commentaryWhy Federal IDR Matters for Physician Payment and Patient Access
Dr. Michael Yoo warns that weakening federal IDR would affect physician leverage and patient access. Halkovich Law separates the advocacy case from the official data and identifies the evidence policymakers should require.
Read the Halkovich Law commentaryNew CMS Audits Reveal QPA Calculation and Disclosure Failures
CMS documented calculation, claim-identification, and disclosure failures in two QPA audits. Halkovich Law explains the findings, their limits, and the records providers should preserve.
Read the Halkovich Law commentaryUnitedHealthcare Says IDR Awards Near 6% of Medical Spend in Some Regions. What Does That Number Actually Show?
UnitedHealthcare reported a striking regional cost figure without publishing the regions, denominator, claim mix, or calculation. Halkovich Law identifies the evidence needed to evaluate it.
Read the Halkovich Law commentaryWhat Replacing Federal IDR with Insurer-Calculated Payments Could Mean for Providers
ASA, ACEP, and ACR oppose a proposal they say would eliminate neutral federal IDR and replace it with insurer-calculated payments. Halkovich Law examines the proposal, the cited data, and a more targeted path to reform.
Read the Halkovich Law commentaryNew CMS Remittance Codes Will Change How Providers Identify No Surprises Act Claims
CMS will require line-item RARCs for certain out-of-network claims in 2027. Halkovich Law explains which codes signal possible federal IDR eligibility and how providers should prepare.
Read the Halkovich Law analysisVirginia Federal Court Reinforces Narrow Review of No Surprises Act IDR Awards
The court dismissed Anthem's collateral claims and found no plausible FAA basis to vacate the awards. Halkovich Law explains the holding, its limits, and what providers should preserve.
Read the Halkovich Law analysisWhat ASA's No Surprises Act Position Means for Anesthesiology Groups
ASA's coalition position puts insurer defaults, nominal offers, QPA reliance, and payment conduct in context. Halkovich Law explains what anesthesia groups should preserve and why the full claim sequence matters.
Read the Halkovich Law analysisWinning IDR Is Not Recovery Until the Award Is Paid
A binding determination does not solve a practice's cash-flow problem until payment arrives. Halkovich Law examines the 30-day rule, the enforcement gap, and the records providers should preserve.
Read the Halkovich Law analysisACEP: The No Surprises Act Must Be Enforced, Not Weakened
ACEP's message to Congress centers the conduct that pushes claims into arbitration: initial payments, defaults, nominal offers, QPA calculations, and compliance after an award.
Read the Halkovich Law analysisPhysician Groups Ask Congress to Strengthen No Surprises Act Enforcement
Emergency medicine, radiology, and anesthesiology organizations presented new figures on insurer defaults, nominal offers, and QPA-related concerns. Halkovich Law examines what the data add to the IDR debate.
Read the Halkovich Law analysisSecond Circuit Limits Private Enforcement of Unpaid IDR Awards
The court rejected an implied private NSA enforcement action, but the binding award and 30-day payment obligation remain. Halkovich Law explains the jurisdictional and practical consequences.
Read the Halkovich Law analysisNew IDR Gateway: What Providers Should Do Now
CMS has opened account creation, with the full filing transition ahead. Halkovich Law explains who must register and what records providers should protect now.
Read the Halkovich Law analysisIDR, Premiums, and the Evidence Congress Still Needs
In response to Politico's reporting on employer concerns, Halkovich Law examines the evidence needed before assigning premium increases to IDR awards.
Read the Halkovich Law analysisFederal Bill Would Restrict Corporate Control of Medical Practices
A neutral brief on the proposed Stop Corporate Takeovers of Physicians Act and the ownership, MSO, clinical-control, and contract provisions it would address if enacted.
Read the news briefPolicy Paper Proposes Scaling Back Federal IDR Arbitration
A source-attributed summary of Paragon Health Institute's findings and its proposed changes for elective and emergency-service disputes.
Read the policy briefCongressional Inquiry Examines Federal IDR Entity Practices
Six certified IDR entities received oversight letters requesting operational, ownership, quality-control, and dispute information.
Read the news briefAn IDR Award Is Not Optional
Halkovich Law examines the federal 30-calendar-day payment rule and the records providers should preserve when a final IDR determination remains unpaid.
Read the Halkovich Law analysisFederal Agencies Add a 17th Certified IDR Entity
Physio Solutions, LLC, doing business as medlitix, has joined the federal IDR roster. CMS currently lists the organization as not accepting new disputes.
Read the news brief1,700 Fewer Prior Authorizations—But Providers Still Need a Verification Plan
UnitedHealthcare's October reduction is meaningful. Halkovich Law explains why practices still need code-, plan-, state-, and patient-specific proof before changing workflows.
Read the Halkovich Law analysisWhen Insurers Downcode Claims, Providers Pay Twice
Halkovich Law examines the reimbursement loss and administrative burden created by recurring downcoding—and the records providers should preserve now.
Read the Halkovich Law analysisWhat the $22 Billion IDR Cost Report Leaves Out
Halkovich Law responds to the Fierce Healthcare report with the missing context: reported award errors, health-plan defaults, nominal offers, and the disputed QPA benchmark.
Read the Halkovich Law analysisWhat Insurer Challenges to the No Surprises Act Mean for Healthcare Providers
Halkovich Law examines an opinion in The Hill about insurer challenges, initial payment offers, IDR outcomes, and award enforcement—then outlines the records providers should preserve.
Read the Halkovich Law analysisWhat the Fifth Circuit's QPA Ruling Means for Healthcare Providers
A federal appeals court rejected important parts of the methodology used to calculate the qualifying payment amount. Halkovich Law examines the decision's implications for QPA review, negotiation, documentation, and federal IDR strategy.
Read the Halkovich Law analysisWhat the Latest Federal IDR Data Means for Healthcare Providers
Halkovich Law examines New York Times coverage and RevGuard's separate response to Wall Street Journal coverage, then considers the practical implications for claim screening, eligibility, documentation, and enforcement.
Read the Halkovich Law analysis