Discussion Topics
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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:
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
To maintain status plan must include statement in plan materials describing
the benefits provided that plan believes makes it grandfathered plan
The plan also must provide contact info for questions and complaints
The following model language can be used to satisfy disclosure:
“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
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
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
$1 billion recovered annually through health subro
$5-6 in recoveries per covered life per year
Lowers premiums as plan rates set on historical costs
Savings passed to employers & employees
Subro included as factor in actuarial calculations
Subro recoveries are revenue - not windfall
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
Alcohol
What is an “Illegal Use of Alcohol”?
Error
Charges arising from provider error may be excluded and are not
considered to be reasonable
Excess
Hazardous Hobby
Subrogation / Third Party Liability
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
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
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
Eligibility Verification
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
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:
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
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
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
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