Chaz Posted March 31, 2011 Posted March 31, 2011 Under health care reform, nongrandfathered health plans, including self-insured plans, must contract with independent review organizations to conduct external reviews of appeals. Under Q/A 9 of the Affordable Care Act Implementation FAQs Part I, the regulators stated that a self-insured plan does not need to directly contract with any IRO and that the plan's TPA can contract with the IRO. That doesn't answer the question whether a plan whose external reviews are being arranged by their TPAs must nonetheless execute a business associate agreement with the IRO. I've seen some secondary sources that say that a BAA is required. Does anyone have any thoughts on this? What are TPAs doing who take on the responsibility of contracting with IROs? As always, thanks for any help.
GMK Posted April 8, 2011 Posted April 8, 2011 I don't have an answer to your OP, but I wanted to express my sympathy regarding your new tag-along "best friend." What a pain. (I'm busy updating my Ignore list.) Don't know if it's relevant, but googling 'Mask of Sanity' gave some interesting links. Sadly, there's no known cure. (I know. Now, he'll be after me, too.)
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