IDR Batching Vs. Bundling
Understand The Key Differences
As billing disputes involving a single item or service are common, there are circumstances when an IDRE can review multiple items or services simultaneously to better streamline the IDR process and reduce costs. Batching and bundling both allow FHAS to review disputes as a group, but only under certain conditions. The terms “batching” and “bundling” are often used interchangeably by parties, but it is important to know they are two distinctly different dispute types. When submitted incorrectly, a resubmission is required. To help ensure disputes are handled properly and efficiently, we have developed a guide outlining FHAS procedures and qualifications for bundled and batched disputes.
What is the difference between a batched and a bundled IDR claim?
Batching allows an initiating party to submit multiple related items or services for a single IDR dispute represented as a single patient encounter, identical service codes, or a Category I CPT code section.
Bundled disputes contain multiple items and services, but are represented by a single service code or single payment by one of the parties involved.
FHAS Batching Guidelines
Due to ongoing litigation related to the No Surprises Act and the lack of a final rule governing batching, FHAS must determine which items and services are considered “related to the treatment of a similar condition.” Currently, FHAS batching rules align closely with those outlined in the No Surprises Act Independent Dispute Resolution Process Proposed Rule Fact Sheet issued on October 27, 2023.
4 Rules for Batching
All four of the following criteria must be met when batching claims:
- Eligibility is limited to items and services billed by the same provider, group of providers or facility, under the same NPI or Taxpayer Identification Number (TIN)
- Payment for the items and services must come from the same group health plan or health insurance issuer.
- All batched items and services need to have occurred during a 30-business day period following the date on which the earliest included item or service was furnished.
- All batched items and services must be related to the treatment of a similar condition.
3 Ways to Batch Disputes According to FHAS’ Definition of “Treatment of a Similar Condition”
- Batch a Single Patient Encounter
- All items and services from the same provider (NIP or TIN) and that were furnished during a single episode of care are eligible to be batched.
- Batch by Identical Service Codes
- You may submit all identical items or services as a batched dispute, regardless of patient.
- Batch by Category I CPT code section
- Create a batched dispute for all services within the eligible radiology, pathology & labs, anesthesiology, or air ambulance code, as specified in current guidance.
FHAS Bundling Policy
What is Bundling?
When multiple items or services from a provider 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.
FHAS Policy on Bundled Disputes
Unfortunately, there is a significant lack of clarity involving bundled disputes. In advance of a dispute resolution, FHAS asks health plans and insurance providers to provide a statement outlining its bundling methodology so that their position is clear to all parties.
Required Statement from Issuer
An authorized representative for the issuer should declare one of two approaches to bundling.
