The college provided a roadmap to the Centers for Medicare and Medicare Services (CMS) Center for Consumer Information and Insurance Oversight (CCIIO). It highlighted that its proposed recommendations are sufficiently accessible, will ease growing case backlogs, and can help safeguard patient access to care.

The recommendations follow a January 5 meeting with CCIIO and include the following:

• The CCIIO should modify the independent dispute resolution process to allow for more batching of disputed claims by the same family of service codes and for services paid within the previous 90 days.
• The CCIIO should jettison a 600% increase in the independent dispute resolution administrative fee (which ranges from $50 to $350; some Independent Dispute Resolution Entity fees are more than $1,200).

Regarding the independent dispute resolution administrative fee, the college said fee increases are often higher than the amount in dispute and may block radiologists and other providers from taking part in the resolution process. If not mitigated, these fees will add to "growing insurer overreach that threatens access to care," according to the ACR.

The college's proposed roadmap would maintain all patient protections in the No Surprises Act, which the ACR supported, and help correct independent dispute resolution implementation without raising patient costs, it said.