Transcript Discussion Topics

Health Care Reform
Opportunities and Challenges
Presented by:
Adam V. Russo, Esq.
CEO
©The Phia Group, LLC – Copyright 1999-2010
Overview
How the Federal Reform Will Affect Our Industry and What We
Need to Accomplish in Order to Comply With Coverage
Requirements and Succeed in the Future
 The Price of Health Care Reform
 Positive Outlook for the Future
 Cost Saving Measures
 The Phia Group Solution
©The Phia Group, LLC – Copyright 1999-2010
The Price of Health Care Reform
Effective as of September 23, 2010:
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Prohibition of Lifetime & Annual Limits
Coverage of Dependents Under Age 26
Prohibition of Rescissions
Coverage of Preventative Services *
Medical Loss Ratio * **
Appeals Process *
Coverage of Emergency Services *
Provider Designation *
* Grandfathered Plans Exempted
** Self-Insured Plans Exempted
©The Phia Group, LLC – Copyright 1999-2010
The Price of Health Care Reform
Effective as of 2014:
 Prohibition of Pre-X Exclusions
 Rating Rules *
 Guaranteed Availability
 Renewability
 Prohibition on Waiting Periods > 90 Days
 Out-Of-Pocket Maximums
 Deductible Maximums
* Grandfathered Plans Exempted
©The Phia Group, LLC – Copyright 1999-2010
Grandfathering
 Some changes end grandfathering according to Interim Final Rules
 The HHS estimates that between 71% and 87% of large employer
plans will be grandfathered in 2011, and between 36% and 66% of
small employers plans will have grandfathered status in 2011
 The Affordable Care Act established two different types of health
care plans:
 New plans – est. after 3/23/10 and grandfathered plans - in effect
on 3/23/10 - Individuals enrolled in these plans may not be
forced to terminate that coverage
 While new plans are subject to all of the health reform rules,
grandfathered plans are not
©The Phia Group, LLC – Copyright 1999-2010
Changes Which End Grandfathering
1.
The elimination of benefits to diagnose or treat a particular
condition
2.
Any increase, measured from March 23, 2010, in a percentage
cost-sharing requirement (such as an individual’s coinsurance
requirement)
3.
Any increase in a fixed-amount cost-sharing requirement other
than a copayment, determined as of the effective date of the
increase, that exceeds the maximum percentage increase, which
is medical inflation plus 15%
4.
Any increase in a fixed-amount copayment that exceeds the
greater of:
a.
b.
$5 or
medical inflation plus 15%
©The Phia Group, LLC – Copyright 1999-2010
Changes Which End Grandfathering
5.
Decrease in employer contribution rate:
a. Plan ceases to be grandfathered if the employer decreases its
contribution rate based on cost of coverage (the amount of
contributions made by an employer) by more than 5%
b. Plan ceases to be grandfathered if the employer decreases its
contribution rate based on a formula (such as hours worked)
by more than 5%
6.
Changes in annual limits:
a. Plan ceases to be grandfathered if it imposes a annual limit on
the dollar value of benefits
b. Plan that imposed an overall lifetime limit on benefits, but no
annual limit ceases to be grandfathered if it adopts an annual
limit at dollar value that is lower than the lifetime limit
c. Plan that imposed an annual limit on all benefits ceases to be
grandfathered if it decreases the annual limit
©The Phia Group, LLC – Copyright 1999-2010
Grandfathering Disclosure
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To maintain status plan must include statement in plan materials describing
the benefits provided that plan believes makes it grandfathered plan
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The plan also must provide contact info for questions and complaints
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The following model language can be used to satisfy disclosure:
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“This group health plan believes this plan or coverage is a ‘grandfathered
health plan’ under the Patient Protection and Affordable Care Act. As
permitted by the Affordable Care Act, a grandfathered health plan can
preserve certain basic health coverage that was already in effect when that
law was enacted. Being a grandfathered health plan means that your plan
may not include certain consumer protections of the Affordable Care Act
that apply to other plans, for example, the requirement for the provision of
preventive health services without any cost sharing. However,
grandfathered health plans must comply with certain other consumer
protections in the Affordable Care Act, for example, the elimination of
lifetime limits on benefits.”
©The Phia Group, LLC – Copyright 1999-2010
Appeal & Review Under
PPACA
On July 23, 2010 the Department of Treasury, DOL and
Department of HHS jointly published Interim Final Rules
relating to Internal Claims and Appeals and External
Review Processes (the “Rule”) under PPACA
 Effective 09/21/10
 Applicable for plan years beginning on or after 09/23/10
 The Rule sets forth directives for plans to implement PHS Act section
2719
 The Rule does not apply to grandfathered plans
©The Phia Group, LLC – Copyright 1999-2010
Step 1: Internal Review Revised
New Internal Review Guidelines:
Under regulations, DOL standard remains in place, but is broadened in 10
ways:
1. Expanded definition of “Adverse Benefit Determination”
2. Stricter Conflict of Interest (“COI”) rules
3. Updated and standardized EOBs
4. Provide new evidence relied upon in the appeal and new rationale
 Right to review “file” / Additional evidence disclosure
requirements
 Right to present “testimony” in appeal by patient
Enforcement grace period until July 1, 2011 for numbers 4, 7, 8, & 10
©The Phia Group, LLC – Copyright 1999-2010
Step 1: Internal Review Revised
New Internal Review Guidelines:
DOL standard remains in place, but is broadened in 10 ways:
5. Notification of urgent care claim determination shortened
 From 72 hrs to ASAP, no longer than 24 hrs
6. New impartiality requirements
7. New notice requirements
8. Culturally appropriate notices
9. Continued coverage requirement
10.Strict compliance and risks for failing to do so
Enforcement grace period until July 1, 2011 for numbers 4, 7, 8, & 10
©The Phia Group, LLC – Copyright 1999-2010
Step 2: External Review Required
New External Review Guidelines:
 PPACA requires plans to provide participants an external review of
claims
 Participant has the ability to seek an independent third-party’s
decision regarding whether the claim should have been covered
 Appears third-party’s decision is binding and unless other
remedies are available under state or federal law
 Seems to mean that following the internal review, the
participant has the choice of the external review or judicial
review
©The Phia Group, LLC – Copyright 1999-2010
Step 2: External Review
Required
New External Review Guidelines:
 Plans must have contracts with IROs that:
 Provide legal experts
 Adhere to time deadlines
 Reviewing guides for IROs include:
 De novo review and freedom from being bound by plan’s findings
 Application of appropriate practice guidelines by IRO
 Consideration of the review criteria developed / used by the plan
 Consideration of the opinion of IRO’s clinical reviewer
 IRO provides decision with specified information
 Plan provides coverage if the plan’s decision is reversed
©The Phia Group, LLC – Copyright 1999-2010
New Procedures Under The Rule
 ERISA preemption does not prevent the state process from applying
to nonfederal governmental plans
 If plan is not subject to state insurance regulation, must comply with
Federal external review processes set forth in the Rule
 State
 Non-grandfathered plans must comply with existing state
external review processes if they include consumer
protections (NAIC Uniform Model Act)
 Federal
 Plan subject to the Federal external review process unless
established by state
©The Phia Group, LLC – Copyright 1999-2010
New Procedures Under The Rule
 Transition period for all plans subject to the existing state external
review processes until July 1, 2011
 Departments will be collaborating with individual states to assist in
incorporating necessary consumer protections:
 Make exhaustion of the internal claims and appeals process
unnecessary in certain circumstances
 Require issuer to pay for the cost of the IRO
 Provide that the IRO’s decision is binding on the plan
©The Phia Group, LLC – Copyright 1999-2010
Potential Issues
Scope
 NAIC Uniform Model Act covers all types of issuers
 The Rule does not establish a standard to apply when a state
external review process does not apply to all types of issuers
 Example: A state may have an external review process in place that
meets all the requirements of the Rule that is only applicable to
HMOs
 An issue arises as to whether the applicability of a state external
review process would be expanded to include other plans subject to
a state external review process
©The Phia Group, LLC – Copyright 1999-2010
Potential Issues
Conflict of Interest (“COI”)
 NAIC Uniform Model Act provides that an approved IRO must have no
COI influencing its independence and the IRO should be random
 The plan is paying the IRO for its decision which is binding not only to
the plan but also to the claimant
 How neutral will the IRO really be?
 Plans are required to contract with at least 3 IROs and rotate claims
assignments
 IROs cannot receive incentives based on likelihood of denial of benefits
 If IRO wants to continue to work with the plan, they may want to keep
their client satisfied which could result in an unspoken COI
©The Phia Group, LLC – Copyright 1999-2010
Potential Issues
Binding IRO Decision
 Internal claims and appeals may be passed over
 If review starts at external level there will be inconsistencies
 IRO has different procedures
Eligible Claims
 The Rule: A claim denied due to participant’s failure to meet the plan
eligibility requirements may not be considered for review
 NAIC Uniform Model Act: No minimum dollar limit on eligible claims
 What types of claims will be eligible for external review?
©The Phia Group, LLC – Copyright 1999-2010
The Aftermath
©The Phia Group, LLC – Copyright 1999-2010
The Aftermath
The Law’s Failures
Health “Insurance” Reform fails to address other causes of rising costs:
1.
Tort reform / Medical malpractice and malpractice insurance
1.
Preventative care / Fitness / Food & Diet
1.
Provider costs / Unfettered billing
©The Phia Group, LLC – Copyright 1999-2010
Health Care Reform Case Law
 Michigan Challenge - Individual mandate as part of Congress’ duty
to regulate commerce
 Federal judge refused to grant a preliminary injunction to block
health reform’s individual mandate, ruling the Commerce Clause
of the U.S. Constitution allows Congress to prohibit economic
“non-activity” (i.e. failure to maintain health insurance and
penalize those who fail to maintain such insurance)
 State of Florida vs. U.S. Department of Health and Human Services
 The Court allows arguments to continue regarding:
 Whether the individual mandate may have exceeded
Congress’ power to regulate trade under the Commerce
Clause
 Whether the mandate coerces and commandeers the states
regarding Medicaid by altering and expanding the program
©The Phia Group, LLC – Copyright 1999-2010
Taking Advantage of Change
 America’s Health Insurance Plans (AHIP) stated that self-funded
plans threaten to deprive the insurance industry of healthy lives that
support large risk pools
 Insurers are concerned about “adverse selection and ability of
smaller and smaller firms to pull themselves out of the exchange
and go into the business of self-funding — which would be very,
very bad for the structure of the exchanges,” said Scott Keefer, VP
for policy development at AHIP
©The Phia Group, LLC – Copyright 1999-2010
Taking Advantage of Change
 "Most of the mandates of the healthcare reform weigh more heavily
on the fully funded industry," said Attorney Anthony Mistretta, of HM
Insurance Group Inc. at SIIA 30th Annual National Education
Conference & Expo, explaining that mid-size and smaller employers
that currently purchase health insurance could instead turn toward
self-insurance.
 Opportunities could come about simply because the status quo
might become unbearable or impossible for employers. Employers
could be finding the process of grandfathering in their current
benefits plan under the new law like having "tied their hands" in
terms of plan design and cost savings.
Source: MyHealthGuide
©The Phia Group, LLC – Copyright 1999-2010
Taking Advantage of Change
 Incentives to self-fund are stronger under reform
 The threshold for self-funding has decreased
 Self-funded employers get the job done cheaper with tailored plan
design, lower administrative costs, and access to claims data
 Self-funded plans may also pull themselves out of the pool because
that way they can avoid State taxes on health insurance premiums
©The Phia Group, LLC – Copyright 1999-2010
Taking Advantage of Change
 Focus on administrative rights
 Empower discretionary authority
 Assert ERISA status (if applicable)
 Delineate fiduciary rights and duties
 Control costs internally
COLLABORATE & INNOVATE
©The Phia Group, LLC – Copyright 1999-2010
Taking Advantage of Change
“Your rights are only as good as your plan language.”
 Enforce the terms of the benefit plan document
 In most circuits we avoid State law only where it is disclaimed in
writing
Importance of “Pre-Emptive Creativity”
If You’re In Trouble, It’s Too Late!
©The Phia Group, LLC – Copyright 1999-2010
Plan Documents
Review the Plan Document
 Plans should ensure they have appropriate discretionary authority
language
 A detailed review and revision of plan document terms and
processes needs to be handled immediately to stay in compliance
Outlook
 Adding additional regulation in the form of external review will only
add cost and further confusion
 How these new requirements will affect the ability of plans and TPAs
to steer clear of conflict and litigation remains to be seen
©The Phia Group, LLC – Copyright 1999-2010
Plan Documents
 Where does the money come from?
 Source of Funding is Self-Funded
 Who decides where the money goes (and how)?
 Identify the Plan Fiduciary
 Assert Discretionary Authority
 Discretionary Authority in Accordance with the Terms of the Plan
©The Phia Group, LLC – Copyright 1999-2010
What’s the Big Deal with
Discretionary Authority?
 Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, 111, 103 L. Ed.
2d 80, 109 S. Ct. 948 (1989)
 Conkright v. Frommert, 2010 U.S. LEXIS 3479 (April 21, 2010)
©The Phia Group, LLC – Copyright 1999-2010
Subrogation vs.
Reimbursement
Subrogation Language
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Assign RIGHT to subrogate / pursue claim
DO NOT CLAIM AUTOMATIC SUBROGATION!
An automatic lien attaches in favor of Plan
Plan MAY commence proceeding against any party for recovery
If possible, let the plan member pay the fees and costs…
Right of Reimbursement Language
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Plan entitled to recover 100% benefits paid:
Without deduction for attorneys’ fees, common fund / made whole
Plan’s equitable lien supersedes statutory rules & state law
Obligation to reimburse regardless of how the settlement is
classified
 Plan’s rights not reduced by covered person fault
©The Phia Group, LLC – Copyright 1999-2010
The Importance of Subro
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$1 billion recovered annually through health subro
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$5-6 in recoveries per covered life per year
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Lowers premiums as plan rates set on historical costs
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Savings passed to employers & employees
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Subro included as factor in actuarial calculations
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Subro recoveries are revenue - not windfall
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1% increase in costs = loss of coverage for 300,000 insureds
©The Phia Group, LLC – Copyright 1999-2010
Overpayments - Right of
Recovery
Right of Recovery is Often Wrongfully Limited to COB Section:
 The plan should include a separate right of recovery provision which
addresses all overpayments
 The plan’s right to recover
 Who the plan may recover from
 Other plans
 Participant
 Provider
 When the plan may recover
 Excluded claims
 Overpayments / excess charges
 Duplicate payments
©The Phia Group, LLC – Copyright 1999-2010
Offset Provisions
 What is the effectiveness of Offset Provisions?
 Will courts allow it?
 Do we have to limit it to accident related claims?
 Do we have to limit the offset of claims to the patient?
 Can we extend it to all claims for all people attached to the Plan
Member (dependants, spouse, etc)?
©The Phia Group, LLC – Copyright 1999-2010
Never Events
Imprudent to address “Never Events” in your policy:
 There is no concrete definition
 Confusion determining what is actually a “Never Event”
 Instead, redefine reasonableness as the basis for the charge
 It doesn’t matter how “fair” the charge amount is
 Consider denying unreasonable services and/or charges
 If a provider’s error causes a need for additional treatments, the
provider should supply those treatments free of charge
©The Phia Group, LLC – Copyright 1999-2010
Exclusions
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Alcohol
 What is an “Illegal Use of Alcohol”?
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Error
 Charges arising from provider error may be excluded and are not
considered to be reasonable
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Excess
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Hazardous Hobby
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Subrogation / Third Party Liability
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Illegal Acts
 Felonies take effort!
©The Phia Group, LLC – Copyright 1999-2010
Usual & Customary
What’s wrong with U&C?
The U&C Garage!
“Classic” U&C states that other
providers in the area determine what
U&C is. If all providers overcharge,
however, then U&C is still excessive!
©The Phia Group, LLC – Copyright 1999-2010
Be Reasonable!
Reasonable and Appropriate
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Most frequent charge
Acceptable from other payers
Actual costs
CMS Cost to Charge ratios
Average Wholesale Price
Manufacturer’s Retail Price
Prevailing charge in the area
 A real cross-section for comparison
©The Phia Group, LLC – Copyright 1999-2010
Maximum Allowable
Maximum Allowable Charge
 The lesser of:
 Reasonable and Appropriate
 Not Excluded by the Plan for any reason
 Negotiated rate
 Actual billed amount
©The Phia Group, LLC – Copyright 1999-2010
Cost Saving Measures
Self-Funding Under Scrutiny
 HHS to study self-insured plans
 Depict the type of employers that self-insure
 See whether reforms encourage employers to self-insure
 Explore extent of self-insured groups’ innovation
 Senate finance committee will see if any fixes are needed
 Studies to compare large group markets with fully insured
policies
©The Phia Group, LLC – Copyright 1999-2010
Self-Funding Under Scrutiny
Annual Reports on Self-Insured Plans
 Report due Sep 2011
 Info from IRS Form 5500
 Plan type, benefit arrangement, financial filings
 Sent to relevant committees
Study on Large Group Market
 Compare characteristics of employer health plans
 Analysis of adverse selection
 Why self-insurance can offer cheaper coverage
 Efficient admin or denial of claims
 Claim denials and coverage changes in relation to economy
©The Phia Group, LLC – Copyright 1999-2010
Mind the Gap
 What is “the gap” and why should we mind?
 The “gap” refers to gaps in coverage which exist between
 Plan document and the stop loss contract
 Plan document and PPO contract
©The Phia Group, LLC – Copyright 1999-2010
Stop Loss Policy Excludes
Claims Covered by the Plan
The “Original” Gap in Coverage
 Plan document excludes one thing
 Reinsurance policy excludes something much broader
 Charges in excess of the usual and customary (“U&C”) amount
are excluded
 Plan defines U&C based upon what other providers in the area
charge
 Reinsurance policy defines U&C based upon average wholesale,
MSRP, CMS pricing, etc.
©The Phia Group, LLC – Copyright 1999-2010
Stop Loss Policy Excludes
Claims Covered by the Plan
The “Growing” Gap in Coverage
 Charges in excess of the usual and customary (“U&C”) amount
are excluded
 Plan defines U&C based upon what other providers in the area
charge
 Reinsurance policy defines U&C based upon average wholesale,
MSRP, CMS pricing, etc.
©The Phia Group, LLC – Copyright 1999-2010
Stop Loss Policy Excludes
Claims Required by the PPO
The “PPO” Gap in Coverage
 Charges in excess of the usual and customary (“U&C”) amount
are excluded by the SPD, and thus, the stop-loss as well
 Plan pays claims in accordance with a PPO agreement
 Stoploss deems claims paid per the PPO agreement to exceed
U&C
 Plan is reimbursed U&C only
©The Phia Group, LLC – Copyright 1999-2010
PPOs vs. Stop Loss
Mandatory Utilization of PPO Network
 PPO & Providers
 The Plan agrees to pay in accordance with the PPO
agreement anytime an in-network provider provides the
service (good faith reliance)
 Must pay billed charges, minus a discount, or risk a breach of
the contract
 If TPA signs agreement it is ultimately responsible to
reimburse provider (breach of contract)
 Pay each provider the amounts set forth in the Provider Rate
Schedule per the agreement
 Stop Loss
 Networks provide ACCESS to discounts in exchange for
reimbursement at agreed upon rates for eligible expenses
 If rates or services are not eligible in accordance with the
SPD, the Plan should choose not to access the network, and
pay OON (in accordance with the terms of the SPD)
©The Phia Group, LLC – Copyright 1999-2010
The Cost of PPOs
Fictional Discounts
 Example: Stent purchased by a hospital at wholesale rate ($3K)
- Hospital bills at $30,000 (with 20% discount)
 SPD (and Stoploss) indicate eligible amount available is more
than $3K, but less than $30K.
 Either Plan is paying provider less than PPO agreement would
suggest, or, is paying more than SPD allows (and thus, more
than the Stoploss will reimburse)
©The Phia Group, LLC – Copyright 1999-2010
Sample PPO Language
User’s Responsibilities
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In the event that Client administers Programs on behalf of Users, it
shall contractually obligate those Users to:
a) timely pay Network Providers the Contract Rates,
b) comply with the applicable terms and conditions of the Network
Provider Agreements, and
c) comply with any applicable terms of this Agreement that may be
the responsibility of the Users, including but not limited to those
pertaining to the administration of the Programs and maintaining
the confidentiality of the information, the Contract Rates and the
terms of the Network Provider Agreements

In the event that Client fails to contractually obligate its Users to
such terms and conditions, Client shall be responsible for those
obligations and shall have the right to terminate this Agreement as
to those Users
©The Phia Group, LLC – Copyright 1999-2010
Addressing PPOs With
Proactive Strategies
PPO Agreement Addendum
 Issue
 Provider would not allow TPA to view hospital agreement before
signing it
 TPA did not want to sign agreement without knowing what the
terms of the agreement entailed
 Result
 TPA refused to sign hospital agreement
 Provider offered TPA an “MOU” allowing access on a case by
case basis, a 25% discount
©The Phia Group, LLC – Copyright 1999-2010
Addressing PPOs With
Proactive Strategies
Access network by choice rather than mandatory usage every time
 Temple University Medical Center v. Group Health Plan, Inc. (E.D.
Penn. Jan. 25, 2006)
 U.S. District Court for the Eastern District of Pennsylvania
dismissed breach of contract claims filed by Temple against GHI,
Oxford, and MultiPlan
 Determined that ERISA preempted claims should have been
paid in accordance with the rates set in its contract with
MultiPlan
 Agreement provided the right to access Temple and discounts
on a non-exclusive basis, there was not a requirement to use
Temple and affiliated providers
 As a result, GHI could choose how to pay the Temple and its
affiliated providers on an in network or out of network basis
©The Phia Group, LLC – Copyright 1999-2010
Addressing PPOs With
Proactive Strategies
“Tether” PPO Agreement to SPD terms
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Eligibility Verification
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The parties agree that:
a. Verification of eligibility is not a guarantee of benefits and
b. Benefits for Covered Services shall be paid in accordance
with provisions of the applicable Benefit Plan

Payment to Contract Providers
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Client shall pay contract providers that portion of the contract
rate that exceeds the copayment, coinsurance and deductible
amount specified in the applicable benefit Plan and which is
not otherwise excluded or limited by such benefit plan
©The Phia Group, LLC – Copyright 1999-2010
Addressing PPOs With
Proactive Strategies
Contract Issue = State Court (Bad) … SPD Issue = Federal Court (Good)
 Radiology Associates of San Antonio v. Aetna Health, Inc. (W.D. Tex.
Mar. 2, 2005)
 “Not the critical factor in establishing ERISA preemption, nor is the
mere existence of some other legal duty between the parties“
 “Is the dependence or independence of the contract and/or the legal
duty on the ERISA-regulated plan."
 Rights and obligations of the parties are defined by reference to the
plan
©The Phia Group, LLC – Copyright 1999-2010
Best Practices
Provider Pushback
Not every provider will be happy…
We’ve got a response for them:
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Similar arguments used in out-of-network scenarios
AOB is consideration… feel free to return the check!
(Explained on next slide)
The language was in place prior to performance
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The administrator’s determination is not arbitrary
©The Phia Group, LLC – Copyright 1999-2010
Best Practices
In Exchange for Providing Services, the Provider has Two Options:
1.
Bill the insured for services and the insured is responsible for
payment

Insured submits the bill to insurer, and the insurer
compensates the insured for the fair market value of their loss
2.
Provider accepts from the insured – as consideration in full for the
medical services provided – an assignment of benefits

Provider only entitled to what the insurer determines is the fair
market value of the loss, exactly as the insured was only
entitled to what the insurer determined was the fair market
value of the loss
©The Phia Group, LLC – Copyright 1999-2010
Best Practices
Overview of Best Practices
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Review every PPO agreement & stop-loss agreement, in light
of the SPD, and each other.
Ensure claims are payable in accordance with the Plan before
accessing a network or utilizing a discount.
Be transparent! Make sure everyone (provider, network,
carrier) knows how you handle claims before they are
received.
When dealing with a potential issue, advise the carrier and
seek an extension – Don’t try to “sneak it by them.”
Remember who the fiduciary is (the plan sponsor) and what
their duty is (to prudently manage the plan assets).
©The Phia Group, LLC – Copyright 1999-2010
We Need to Do Better!
As an industry, you are identifying one case for every 300 employee
lives…
As an industry, you are recovering about $5 to $6 per employee.
There are cases which aren’t being identified…
… There are claims being settled, which you don’t know about…
Enforce your rights!
©The Phia Group, LLC – Copyright 1999-2010
The Phia Group Solution
Our Mission: Reducing the Cost of Health Plans Through
Innovative Technologies, Legal Expertise, and Focused, Flexible
Customer Service
 Overall Goal – Sustain the Viability of the Self-Funded Market
 Purpose – Limit the Increasing Costs of Health Care
 Passion – Finding Innovative Ways to Identify Savings
©The Phia Group, LLC – Copyright 1999-2010
Honors and Awards
©The Phia Group, LLC – Copyright 1999-2010
The Phia Group Services
Claims Recovery Services
 Subrogation and Right of Reimbursement
 Attorney Consultation and Defense
 Second Pass Recovery Audit
 Overpayment Recovery
 Coordination of Benefits
Plan Document Services
 Innovative Plan Document Design
 Plan Document Review and Revision
 Regulatory and Legal Compliance Updates
 Third Party Agreement Review
Consulting and Special Services
 Claim Processing Evaluation
 Stop Loss Claim Analysis
 Plan Administration Review and Defense
 Dispute Resolution
©The Phia Group, LLC – Copyright 1999-2010
Questions?
Adam V. Russo, Esq.
[email protected]
866-THE-PHIA
Free Webinar
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