Audio Q&A

Out-of-Network Reimbursement and No Surprises Act Q&A with Jeffrey Halkovich

Jeffrey Halkovich discusses how providers can identify eligible claims, prepare for federal IDR, document their payment position, and reduce administrative loss before deadlines expire.

Published August 15, 2026 32 minutes 34 seconds Provider reimbursement discussion

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This conversation focuses especially on anesthesia and other out-of-network provider groups navigating the No Surprises Act. Use the chapter guide to jump directly to a topic.

Full recording

Out-of-Network Reimbursement Q&A

Jeffrey Halkovich on eligibility, QPA payments, open negotiation, IDR documentation, and protecting claims from administrative loss.

Chapter guide

Claims can be lost before arbitration

Jeffrey's central operational point is that a viable dispute can disappear before its merits are considered if the claim is not identified and acted upon in time.

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Jeffrey Halkovich: So really what it comes down to now is that, yes, the strategy has changed, but it's very important what group a provider works with, because most of the loss happens on the administrative side, on failing to identify claims, whether at all or in a timely manner.

Why the initial QPA offer may persist

In discussing his practice experience, Jeffrey describes open negotiation as a required stage that often does not produce a materially different payer offer. That observation is not a universal statistic for every payer or claim.

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Jeffrey Halkovich: What you'll see a lot is, yes, that initial QPA payment is usually the offer that you see persist through the whole process. It's not as though, you know, you'll send in a bill on an original claim, you'll get a low payment for the QPA because the No Surprises Act applies. Because you're required to engage in the open negotiation process, you do. But what you 99% of the time find is that there's no meaningful offers that are made. There's no meaningful negotiation. And there's very rarely an offer that gets to the point where, you know, you would be willing to accept to settle that claim.

Documentation can sharpen the IDR presentation

The discussion identifies provider credentials, training, facility context, case mix, teaching status, and procedure acuity as information that may help organize a claim-specific submission.

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Jeffrey Halkovich: Just getting, you know, really good CVs from the doctors, understanding their training and their history, understanding the facilities where they're doing these cases, what type of cases traditionally get done there. Are they teaching hospitals? Are they not? Looking at the acuity of the procedures and kind of documenting all this stuff. Yeah, that's where I think you can make an impact more so.

The most expensive administrative mistake

For higher-volume provider groups, Jeffrey emphasizes that many comparatively smaller claims can add up to meaningful revenue. Identification, staffing, and timely action therefore matter at the portfolio level.

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Jeffrey Halkovich: And we've touched on it, and it's the same theory. It's working with a group that, one, doesn't know what they're doing, doesn't have the staff to identify the claims, doesn't move on the claims in a timely manner because of the volume of claims that anesthesia generates. They're generally more volume, lower dollar than lower volume, higher dollar claims.

What I see that they're making is administratively losing those claims to IDR by not having the proper people or the proper staff identifying and taking action on it. Once you're in a situation where legally and factually it applies, like we spoke about, if you take no action on it, there's no more money coming. You can't go after the patient anymore. So you're just watching the claims die.

The billing company and the RCM company and the IDR company that you work with—it's critical that things don't get lost. I see so many times things getting lost that can turn into real revenue. Small-dollar claims, people don't—but they add up. And when they add up en masse, they create a problem.

Frequently asked questions

What does Jeffrey Halkovich discuss in this audio Q&A?
The discussion covers out-of-network reimbursement, No Surprises Act claim eligibility, QPA-based initial payments, open negotiation, federal IDR documentation, and claims lost through administrative delay.
Who is this reimbursement discussion most relevant to?
The conversation places particular emphasis on anesthesia groups and is also relevant to healthcare providers evaluating out-of-network claims, federal IDR opportunities, and recurring insurer underpayments.
Is this audio Q&A legal advice?
No. The recording and accompanying summaries provide general educational information. They do not create an attorney-client relationship or determine the correct approach for a specific claim.
Next step

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