Comment on FR Doc # 2010-10054

Having to track disclosures for payments will certainly put an undue burden on practices. No longer is it as simple as submitting a claim form to an insurer (to include Medicare and Medicaid). Depending on the circumstances, we may have to submit additional information to a payor in order to get the claim paid. With one of our nations largest insurers, we currently appealing and re-appealing claims that should have paid going back to 2007. There are known failures by payors to process claims on appeal when there are denials. We have supplied the National health plan I reference above with informaiton on >$200,000 worth of claims that have either been denied incorrectly, not processed per member benefits, or simply ignored. They are working on this as a "project." I think it would be a waste of time and resources to have to keep up with every bit of information that we have to supply to get claims paid just so a patient can ask for it at a later date. Add another layer of complexity to our industry and you'll see health care costs continue to escalate. If we have to keep up with everything we do regarding claims payment then we may as well drop all of our contracts and work on a straight fee for service basis.