Are there alternative approaches payors can use to calculate and segregate HCRA surcharge obligations between multiple payors?
There may be other viable options for calculating the segregation of HCRA surcharge obligations between multiple payors. Payors using other approaches must ensure that the total value of surcharges due is fully reflected in any shared billing arrangement. Further, any approach which would shift normally recognized (as described in the responses to the previous two questions) surcharge obligations between multiple payors must have the concurrence of the payor which will be incurring a larger surcharge obligation from that which would be attributable under the approaches previously recognized by the Department. In all instances, payors must ensure appropriate (as described in the responses to the two previous questions) aggregate pool funding levels and notify providers of such approaches and arrangements when remitting payments.
