Out-of-Network Radiology Claims Fall

Is out-of-network billing – when a patient receives care outside their insurance network – still a problem in radiology? A new study in JACR shows that out-of-network commercial claims have dropped dramatically since 2007.

Out-of-network healthcare has been the focus of a number of legislative efforts in recent years as lawmakers try to protect patients from the financial sting of getting a big bill for services rendered outside their provider’s network.

  • Probably the centerpiece of this effort is the federal No Surprises Act, which went into effect in January 2022; not only did it cap the amount that patients can be billed for out-of-network services, but it created an independent dispute resolution mechanism for adjudicating disagreement between providers and payors over how much they should be paid.

The IDR mechanism has been the focus of legal wrangling in recent months, but the new study in JACR indicates that it might not be getting much use after all, at least in radiology.

Researchers from the ACR’s Harvey L. Neiman Health Policy Institute analyzed 80M commercial claims for radiology services from 2007 to 2021, finding…

  • Out-of-network radiology claims fell dramatically (to 1.1% vs. 13%)
  • Out-of-network claims fell for inpatient stays (to 1.4% vs. 10%)
  • Claims also fell for emergency visits (to 0.4% vs. 3.9%)
  • By modality, most claims were for X-ray (57%), followed by ultrasound and CT (15% each) 
  • By 2021, radiologists practiced almost exclusively in-network

What’s the reason for the dramatic decline? The study authors credit good-faith negotiations between radiology practices and commercial payors, as well as the impact of state surprise billing laws (the study period occurred before the federal No Surprises Act went into effect).

  • Other possible factors include consolidation among practices, hospitals, and payors; expansion of academic centers into communities; and the COVID-19 pandemic.   

The Takeaway

The JACR study is welcome news for both patients and radiology practices. Patients are less likely to be hit with surprise medical charges, while practices are less likely to have to fight through the IDR process to resolve claims. In the end, everybody wins – even insurance companies.

Envisioning A Difficult Future

S&P Global Ratings’ decision to downgrade Envision Healthcare might have been largely overlooked during another busy healthcare news week, but it could prove to be part of one of the biggest stories in healthcare economics.

About Envision – The private equity-backed mega practice employs more than 25k clinicians across hundreds of US hospitals, including roughly 800 radiologists who perform over 10 million reads per year. 

The Downgrade – S&P downgraded Envision Healthcare to ‘CCC’ (from CCC+) and assigned it a ‘Negative’ CreditWatch rating, citing the company’s “inadequate” liquidity, a missed financial filing deadline, and a challenging path forward. Envision owes $700M by October 2023 (and more after that), but S&P expects the company to end 2022 with less than $100M in cash, risking more short-term downgrades and bigger long-term disruptions.

The Background – If you’re wondering how Envision found itself in this situation, a recent Prospect.org exposé has some answers (or at least its version of the answers):

  • When private equity giant KKR acquired Envision in 2018, it burdened the company with billions in debt, including a $5.3B first-lien term loan due in 2025
  • KKR’s initial strategy involved keeping most of Envision’s clinicians out-of-network (and earning higher surprise billing rates), but Envision moved many of its physicians in-network amid public backlash and looming legislation 
  • Ongoing surprise billing legislation spooked investors, causing Envision’s first-lien term loan to trade for 50 cents on the dollar in early 2020, before bouncing back to a somewhat-less-distressed 70-80 cent range later that year
  • The COVID pandemic further strained Envision’s finances, as many of its core specialties saw major volume declines (emergency, anesthesiology, radiology, GI, etc.)
  • Envision avoided bankruptcy thanks to an estimated $100M CARES Act bailout and help from its creditors
  • The final surprise billing legislation turned out to be pretty favorable for Envision, but not as favorable as back in the pre-legislation days
  • As of March 2022, Envision’s $5.3B first-lien term loan was still trading in distressed territory (73 cents), and it has other loans to pay off too

The Path Forward – It’s hard to predict how this will work out for Envision, although Prospect.org suggests that it might involve KKR splitting Envision into two companies. One could be saddled with all the debt and destined for bankruptcy, while the other entity (and KKR) could emerge “unscathed.”

The Takeaway

For many in healthcare this is a cautionary tale about what can go wrong when private equity influences are combined with an over-reliance on a disputed business model (in this case surprise billing) and a global pandemic. It also makes you wonder if other mega practices are in similar situations.

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