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Independent review vendors, expanded IDR options offered as path to fairness and speed
Summary
Experts from Improve Health and private vendors told the committee Kansas could adopt independent IDR/IIDR vendors or outsource surveys to catch up with backlogs. They outlined accreditation, timelines and cost models and said states can contract quickly if statutes and procurement rules allow it.
Consultants and vendors who run independent review or survey contracts told the committee Kansas can reduce backlog and improve perceived fairness by adopting independent IDR/IIDR vendors and, where needed, contracting outside survey teams.
Bailey Brockmeier, managing director of IDR/IIDR at Improve Health, described the purpose of IDR and IIDR processes: IDR is a nonlegal, state-run informal review that lets facilities challenge survey findings; IIDR (created under the Affordable Care Act) is a separate independent review available when civil monetary penalties are imposed. Brockmeier said federal rules in the State Operations Manual (chapter 7) set minimum requirements for IDR and require independence for IIDR reviewers. She told the committee Improve Health holds URAC accreditation and follows conflict-of-interest and data-security standards; the company typically returns recommendations to states within about 16–18 calendar days after assignment.
Charlene Pachek Belitsky and Charlene Bea (Improve Health reviewers) described how an IIDR reviewer examines the written survey record and facility rebuttal and issues a recommendation to uphold, delete, or amend deficiencies. Improve Health and other accredited independent organizations provide standardized written rationale for recommendations that states may accept or forward to CMS, which has final authority.
Private survey contractor CertiServe told the committee it provides turnkey or supplemental survey services and can be mobilized quickly once a state contract is executed. Bob Foyer, CertiServe founder and CEO, said the procurement step and budget authorization are the main constraints: once the contract exists, CertiServe can start surveys within 30–60 days and often in a week for emergency assignments. He said pricing models vary (flat fee per survey, per-tag fees, or blended rates) and states often use multi-year contracts and purchase orders to control budgets.
Vendors and consultants identified practical considerations for Kansas: requirements to secure CMS approval for an IIDR approach; the need to ensure reviewers have clinical and regulatory expertise; and the ability to stand up portals and secure data exchange (the vendors highlighted URAC accreditation as a sign of systems maturity). Vendors suggested states could pilot independent IIDR for a year or sign a standing contract so the state can call on outside capacity during staffing shortfalls.
Ending: Committee members asked KDADS to explore contracting options, to provide a list of prospective costs for turnkey or supplemental survey services, and to consider an independent IIDR panel or vendor as a short-term measure while KDADS implements pay and recruitment changes.
