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28 DALLAS MEDICAL JOURNAL • October 2021
There is still time to ensure that the
agencies understand the physician’s
perspective on the implementation of this
legislation. TMA and five specialty societies
have taken the first step by submitting
comments for the NSA Part 1 IFR on September
7, 2021. The TMA and specialty
society comments provide an in-depth
description of the QPA methodology issue
and provide recommendations on how to
create a fairer IDR process.(2)
The NSA Part 2 is slated to be published
soon, and this regulation should provide
more detail on the IDR process, transparency
measures, and price comparison
tools, as well as air ambulances and
enforcement. Although this IFR includes
many strong consumer and patient protections,
the agencies acknowledge that the
true impact of the NSA on overall market
dynamics—such as premiums and network
negotiations—cannot be assessed until we
have rules on the IDR process. The IFRs
on these forthcoming rules are “interrelated,”
and the agencies expect to include
additional analysis of the NSA’s broader
market impacts in future regulations. (1)
Rules on other NSA provisions in Part
3, including insurance card requirements,
continuity of care, provider network directions,
and prohibition on gag clauses, may
not be published until next year.
As members of DCMS, we can have an
impact by using the open comment period
for all three parts of the NSA IFR. We need
to be strategic and clear on our requests
and use our collective voices to address
the issues in the NSA IFR before final
adoption. Please read the proposed rules
and submit your comments before these
regulations are finalized. We must vocalize
our concerns to ensure that the regulation
is changed to ensure patient protections
are maintained and viable practices are
possible. DMJ
Dr. Christopher Cook is a private
practice anesthesiologist in Dallas/
Fort Worth, currently serving as Chair of
Communications for the Texas Society of
Anesthesiologists. He is the former editor
of the TSA Bulletin. An active member of
DCMS since 2010, he currently serves as
a member of the DCMS Socioeconomics
Committee and as a DCMS delegate in the
TMA House of Delegates.
The views, information, or opinions
expressed in this editorial are solely
those of the individual(s) involved and
do not necessarily represent those of
Dallas County Medical Society (DCMS),
its employees, or the Board of Directors.
DCMS makes no representations as to the
accuracy, completeness, or correctness of
any information provided herein and is not
responsible for its content.
Dallas medical professionals look to the
Dallas Medical Journal and its community
of peer contributors as a valued resource
for Dallas County medical information.
Our goal is to provide insights on various
topics, including patient advocacy,
legislative issues, current industry
standards, practice management,
physician wellness, and more.
The Dallas Medical Journal selectively
accepts articles from industry
professionals that meet our editorial
guidelines. We always seek original,
informative articles that ultimately will be
a useful source to give our professional
readers a broad yet unique reading
experience.
If you are interested in
submitting an article for consideration,
or have additional submission questions,
please email Pamela Lowery at
pamela@dallas-cms.org.
Submit your comments on the Interim
Final Rules during the open comment
periods:
Regulations.gov OR contact your
Congressman at house.gov and express
your concerns.
References:
1. https://www.healthaffairs.org/do/10.1377/
hblog20210706.903518/full/
2. TMA No Surprises Act Article and Comment Letter (see
upcoming link)
3. TSA No Surprises Act Comment Letter https://drive.google.
com/file/d/1Rplv3e6c0Sg8YSiOsVmUoqNbxK9VdWUt/view
4. ASA No Surprises Act Article and Comment Letter https://
www.asahq.org/advocacy-and-asapac/fda-and-washingtonalerts/
washington-alerts/2021/09/asa-provides-feedback-onfirst
set-of-federal-rules-for-no-surprises-act