Explore our latest resources, where OIG's data really points, and where to find us next. ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­    ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏  ͏ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­ ­  
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July 2, 2026

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The Cooling Off Period: What Providers and Health Plans Need to Know

 

What is actually changing with the cooling off period under the final rule for the federal IDR program? To help clarify both the ongoing rules, the coming changes, and their timing, FHAS is offering two new tools to support parties.

 

First, a new guide to the cooling off period explains which claims are subject to the cooling off period, how long it lasts, what will change under the final rule, and when those changes are coming.

 

Second, FHAS has launched a new Cooling-Off Calculator which parties can use today to determine cooling off period dates and new dispute initiation timeframes. FHAS can help your team understand, anticipate, and implement changes directed by the final rule.

 

Contact us for a consultation today!

 

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Prior Authorization: What OIG's Medicare Advantage Data Really Shows

 

In June, federal health officials released significant reports on prior authorization for post-acute care. The data demonstrated steep denial rates for facility-based post-acute care and high overturn rates on appeal, and it made headlines across national and trade media outlets.

 

The underlying issue identified in the report received less attention: namely, that the prior authorization process has problems on multiple sides of the transaction. Sweeping solutions that eliminate prior authorization altogether will only shift the challenges that plague the process to other payment integrity review activities.

 

In a recent post, FHAS explored how a prior authorization process that functions well — with objective, evidence-based determinations and documentation that supports them from the start — serves all these interests simultaneously.

 

LEARN MORE

In Case You Missed It

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FHAS Perspective on the Final IDR Operations Rule

 

As the federal government made clear in the recently announced Final IDR Operations Rule governing the federal Independent Dispute Resolution (IDR) program, the goal of the new regulations is to boost transparency, process efficiency, and effectiveness for all.

 

At FHAS, we view it as our role to help parties understand the enhancements, meet the first wave of change, and prepare for the operational updates that will go into effect over the next year.

 

To help, we will continue to communicate regularly as additional guidance emerges, the federal Gateway – a new portal for the process – begins to phase in, and effective dates and compliance deadlines approach.

 

For early guidance, we have two new resources for you:

  • Video - FHAS Perspective on the Final IDR Operations Rule
  • Blog - The IDR Final Rule is Out: Now What?

FHAS is here to ensure neutral, transparent, and timely arbitration and resolution. Making the IDR program work is our job. Rely on us to support your implementation of the new regulatory framework for IDR. 

Read Our Featured Article In Modern Healthcare

 

The new Federal IDR Final Operations Rule is here, and the biggest question for payers and providers is how and when to put it into practice.

 

In a new article featured in Modern Healthcare, FHAS CEO Jim Bobeck breaks down the key changes — from the $15 administrative fee already in effect to clearer eligibility standards and a phased compliance timeline that runs well into the next year. 

TAKE A LOOK

Events

Look for us at the following upcoming events! If you'd like to schedule time with us at any of the below events, please visit our event page using the link below and fill out the form.

August 23-26 National Association for Medicaid Program Integrity (NAMPI)
VIEW EVENTS

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Disclaimer: The content of this email is intended for general informational purposes only. Federal Hearings and Appeals Services, LLC. (FHAS) strives to ensure the accuracy and completeness of the information provided but makes no representations or warranties, express or implied, about the accuracy, reliability, suitability, or availability of the content for any purpose. Any reliance on the information provided is solely at your own risk. The content shared does not constitute legal, financial, or professional advice and is not binding on Federal Hearings and Appeals Services, LLC. (FHAS) or any federal government agencies. This email and its contents are subject to change without prior notice.

 

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