Bundling: Combining Services or Claims for Simplified Processing
Understand when multiple items or services can be grouped into a bundled payment and how that affects Federal IDR submissions.
What
is bundling?
When multiple items or services from a provider (facility or air ambulance) are billed or paid/denied under a single service code, such as a Diagnosis Related Group (DRG), it is considered a bundled arrangement for the purposes of the Federal IDR process.
Notice of Independent Dispute Resolution forms for bundled disputes must indicate the items or services were bundled.
An entity cannot add Dispute Line Items that were not included in the original submission.
Bundled Payments
Bundled payments refer to a single payment method that covers multiple related services delivered during a defined episode of care, such as the examples below.
- Instead of paying for each individual service separately, a bundle makes a single payment for a defined episode of care.
- This episode can include services like hospitalization, post-acute care, and physician visits, all related to a specific condition or procedure.
- A plan can make an initial payment as a bundled payment (or can specify that a notice of denial of payment is made on a bundled payment basis).
Commence as a IDR Entity
The Department of Health and Human Services, the Department of Labor, and the Department of the Treasury have certified Livanta LLC DBA Commence to serve as a certified independent dispute resolution (IDR) entity in the Federal IDR process between out-of-network providers, facilities, or providers of air ambulance services and group health plans, health insurance issuers in the group and individual market, or Federal Employees Health Benefits (FEHB) Carriers. If an out-of-network provider, facility, or provider of air ambulance services and a health plan, issuer, or FEHB Carrier cannot agree on the payment amount for an out-of-network item or service provided on or after January 1, 2022 that is covered by the No Surprises Act, as a certified IDR entity, we can be selected to determine the payment amount.
IDR Guidance
See IDR Guidance Page 33 Section 10.2
Contact CMS
Contact CMS About the IDR Process
Any inquiries related specifically to the Federal IDR process, or to initiate a dispute, should be directed to the official CMS IDR email: federalidrquestions@cms.hhs.gov.