Below is the HillCo client report from the September 9 Independent Review Organization Advisory Group meeting.
Please see attached for the Informal Proposal on Independent Review Organizations (IRO) and below for general discussion.
Timeline:
Formal proposed rule posted by October
30 day comment period
Formal public hearing
Adoption
HB 2645 required revisions to IROs
Fee section received the most comments during the informal rule posting, the rest of the rule received very little comments
General Discussion
- Medical Necessity is not defined in a policy
- 2 ways of defining depending on discussing health care or workers' comp
- Not a lot of nationally recognized IRO accrediting bodies
- Getting accreditation puts an IRO on a faster track, but it is costly and TDI recognized that so they did not require it in the rule
- IRO requests end at noon on Friday
- 3 day turnaround in life threatening situation
- Concerned that this delay could be very dangerous for actual life threatening situations
- Moved to a different computer platform, and haven't identified any glitches to date
- Comments received about fees were either requesting to raise the IRO fees, or requesting to lower the IRO fees
- Many doing the IROs have justifications to raise the fees
- No decision has been made yet, but they will be in the formal rules
- Texas was the first state to utilize IROs in 1997
- TDI needs to know if IROs are not getting paid timely by carriers
- Utilization Review Act changed 2 years ago to include experimental and investigational
- Comment that fees should be increased due to simple inflation
- Other states fees vary considerably from Texas
- 75% of IRO decisions are in workers' comp, 25% are in health care
- Why is there a tier 1 and tier 2 in the rule?
- That is the way it was set up in 1997 and has not been changed since – doesn't know why it was initially set that way
Advisory Group decided to adopt a more formal structure and meet quarterly
They will meet after the formal proposal is posted in the register
Will elect a Chair at the next committee meeting