Empowering healthcare providers against rising payer denials

https://www.healthcaredive.com/spons/empowering-healthcare-providers-against-rising-payer-denials/712098

In the rapidly evolving landscape of U.S. healthcare, the tug-of-war between payers and providers is continually intensifying, raising the stakes on the strategic maneuvers that shape the industry’s financial and operational dynamics.

The crux of the issue lies in the increasingly sophisticated strategies employed by insurance companies to deny claims: a move that ostensibly aims to safeguard their bottom lines, often at the expense of provider sustainability and patient access.

The rise in denial rates is more than a mere statistic; it’s a symptom of a broader systemic challenge that calls for strategic foresight and robust expertise. In this intricate environment, providers face numerous administrative challenges, working to balance clinical decisions with financial sustainability. 

Drawn from in-depth proprietary analytics, clinical regulatory expertise and decades of experience, CorroHealth addresses what is needed to successfully combat payer denial tactics. Broader industry trends, such as the shift towards value-based care and the increasing emphasis on patient-centric models, will continue to disrupt the historic provider business model. CorroHealth’s insights offer a beacon for steering through these turbulent waters. Their strategic recommendations, from optimizing contract negotiations to leveraging data analytics to managing payer denials, to formalizing escalation paths, reflect a comprehensive approach to mitigating the adverse effects of ever-shifting payer denial tactics.

Delving deeper into the anatomy of payer denials reveals a long-term pattern of deliberate complexity designed to wear down provider resilience. By dissecting the layers of denial management, from initial claim submission to final resolution, CorroHealth uncovers pivotal areas where targeted interventions dramatically shift outcomes in favor of healthcare providers.

This process involves a granular analysis of denial codes, predictive analytics to pre-empt possible denials and rigorous training staff to maneuver through the intricate appeals process effectively. 

Taking a proactive stance towards payer contract management, their approach emphasizes the importance of scrutinizing the fine print and negotiating terms that anticipate and mitigate denial strategies. CorroHealth advocates on the providers’ behalf for clearer definitions of medical necessity, timely filing limits and transparent appeal processes. By equipping providers with negotiation tactics grounded in comprehensive data analysis and a deep understanding of payer methodologies, their contracts become a tool for protection against denials, rather than a source of vulnerability.

Woven throughout this work is CorroHealth’s commitment to advancing the dialogue between payers and providers toward a more equitable healthcare system. Through forums, partnerships and collaborative initiatives, CorroHealth bridges the gap between these two entities, fostering an environment where mutual understanding and respect pave the way for innovative solutions to longstanding challenges.

Hospitals and health systems require an experienced partner to navigate the complexities of the healthcare landscape, balancing financial sustainability with top-tier patient care. CorroHealth offers a comprehensive suite of solutions to address challenges associated with payer denials, enabling providers to recover lost revenues and uphold the fundamental goal of accessible, high-quality patient care. Beyond financial strategies and operational adjustments, the narrative calls for a more productive and transparent dialogue between payers and providers. This aims to encourage an ecosystem where financial sustainability and high-quality patient care are complementary facets of holistic healthcare delivery.

Facing these challenges, the importance of strategic partnerships becomes increasingly vital for healthcare providers. Such alliances are indispensable in maneuvering through the complex healthcare landscape and are strengthened by CorroHealth’s comprehensive understanding of the payer-provider dynamic and dedication to fostering innovation. A collaborative approach is essential for progressing towards a healthcare system characterized by greater equity and efficiency.

The industry stands at an existential crossroads. The insights and strategies shared by CorroHealth serve as a testament to the company’s expertise and its dedication to shaping a future where healthcare is accessible, affordable and effective for all. 

Trauma center hospitals charged above-market prices for non-trauma care

Prices for non-trauma inpatient admissions were 4.4 percent higher at trauma center hospitals than at hospitals without a trauma designation.

Hospitals designated as trauma centers charged higher prices for non-trauma inpatient admissions and emergency department visits compared to non-trauma center hospitals, a Health Affairs study found.

Hospital prices are the largest driver of rising healthcare spending in the commercial market and are often influenced by the structure of hospital markets. Trauma centers are a critical aspect of the hospital market as they are highly regulated and endowed by regulators with monopoly power over trauma patients in their service areas.

In most states, regulations are designed to encourage the entry of new trauma centers in areas that do not already have one and restrict new entry into areas that already have a trauma center. Additional regulations often require all trauma patients within an area to be transported or transferred to the designated hospital serving the area.

These restrictions create local monopolies for hospitals that are designated as trauma centers. Those in favor of the regulations argue that the monopolies are necessary to ensure each trauma center has sufficient volume to support high-quality and low-cost care. However, this structure could allow hospitals with market power over trauma services to raise prices for non-trauma services.

Researchers used claims data from 2011 to 2018 to assess whether hospitals designated as trauma centers use their market power for trauma services to receive above-market rates for non-trauma services. The sample included 2,000 hospitals with more than two million inpatient admissions and ten million emergency department visits over the study period.

The share of hospitals included in the sample serving as trauma centers increased from 21 percent in 2012 to 28 percent in 2018, resulting in a net addition of 138 trauma centers. The share of non-trauma inpatient admissions and emergency department visits at hospitals serving as trauma centers also increased between 2012 and 2018.

Hospitals serving as trauma centers every year from 2012 to 2018 were categorized as an always trauma center. Opened trauma centers were those not serving as a trauma center in 2012 but serving as one by 2018. Hospitals serving as a trauma center in 2012 but not in 2018 were closed trauma centers, and hospitals that did not serve as a trauma center at all during the study period were called “never trauma centers.”

The average price for non-trauma inpatient admissions among all hospitals was $21,112. Always trauma center hospitals had a higher average price of $22,568 per inpatient admission. The average price per admission was $22,097 at opened centers, $20,589 at closed centers, and $19,769 at never centers. Emergency department prices were similar, with always and opened center hospitals having higher prices than closed and never trauma center facilities.

Always trauma center hospitals were generally larger compared to the other hospital types and were more likely to be in more concentrated hospital markets. The average new injury severity score among emergency department visits in never trauma center hospitals was smaller compared to scores at other hospitals. The average MS-DRG weight for always trauma center hospitals was 1.61 compared to 1.54 for opened and never trauma center hospitals.

Holding these patient and hospital characteristics constant, prices for non-trauma inpatient admissions were 4.4 percent higher in hospitals with trauma center designation than at non-trauma center hospitals. Prices for non-trauma emergency department visits were 5.2 percent higher in trauma center hospitals.

“The results presented here provide an example of an important challenge: How to ensure access to specialized services and protect public health while also accounting for and possibly managing the effects of concomitant market failure,” researchers wrote.

“Our findings provide empirical support for the notion that provider market power in one area can be leveraged to affect prices in other areas.”

The No Surprises Act limits the amounts that hospitals can charge to out-of-network patients for emergency services, including trauma services. This may help limit trauma emergency cross-service leverage pricing, researchers said.

One third of hospitals take legal action against patients with outstanding medical bills, study finds

Nearly 50% of U.S. adults report struggling to keep up with the cost of healthcare, with four in ten ringing in the new year with medical debt. Medical debt is a major burden that often forces people to delay–and sometimes forgo–access to care. Not only do outstanding medical bills undermine health, but they also represent the most common type of collections, with estimates ranging anywhere from $81 to $140 billion

With problematic hospital practices gaining national media attention – including rejecting appointments for patients with outstanding medical bills and going so far as to sue such patients – the issue of medical debt is front and center for many Americans.

A glimpse into the state of hospital billing practices

Hospital watchdogs have started collecting valuable data on hospital billing practices to inform patients about these practices and potentially put pressure on hospitals to improve.

In an effort to capture the varied nature of hospital billing and collection practices, the Lown Institute is building a database of financial assistance policies and billing and collection practices across 2,500 hospitals with the support of Arnold Ventures. Initial results are expected to be available in mid-2024 with a full report issued in 2025. 

Also interested in evaluating the current state of hospital’s financial practices, in 2021, the Leapfrog Group added questions to their hospital survey around billing and collections. Researchers from the Leapfrog Group, Northwestern University Feinberg School of Medicine, and Johns Hopkins University School of Medicine published a recent analysis of this data in JAMA where they found that many hospitals are still falling short when it comes to billing ethics. Although the data set of 2,270 hospitals was not nationally representative, it provides an interesting glimpse into the billing practices of some U.S. hospitals.  

Here are the key takeaways: 

  • 754 hospitals (33.2%) reported that they “take legal action against patients for late payment or insufficient payment of a medical bill.” Rural hospitals were 38% more likely than urban hospitals to take legal action against patients. 
  • 1,020 (44.9%) hospitals did not routinely send patients itemized bills within 30 days of final claims adjudication or date of service for patients without insurance.
  • 125 (5.5%) hospitals did not provide access to billing representatives capable of investigating billing errors, offering price adjustment, and establishing payment plans.

Ultimately, only 38% of surveyed hospitals reported meeting all three proposed billing quality standards. Interestingly, hospitals with worse Leapfrog safety grades were less likely to meet all three billing standards compared to hospitals with better grades. It’s not clear what’s behind this pattern, but it could be an issue of capacity (hospitals with more resources and staff have an easier time abiding by safety protocol and billing standards), or potentially profiteering (hospitals more concerned with making money may be both understaffing hospitals and suing patients).

So, how can we encourage better billing practices and reduce harm caused by medical debt?

The JAMA study authors recommend standardizing measurement and reporting of hospital billing practices to “increase accountability, reduce variation in billing practices, and reduce barriers in access to care in the US.” 

Some states are taking these recommendations to the policy-level, working to make healthcare more affordable for patients. To date, eight states limit medical debt interest and two states restrict credit reporting of medical debt. Current policy proposals on the docket include New York’s Senate Bill S5909B, which seeks to ban hospitals from suing patients making less than 400% of the federal poverty level (FPL).

This research is important to not only provide further insight into how hospitals financially support, or undermine, their patients, but also inform policy efforts to improve healthcare affordability and hospital accountability moving forward.

New York governor to curb hospitals suing patients

New York Gov. Kathy Hochul has vowed to protect New Yorkers from medical debt, limit hospitals’ ability to sue patients and expand financial assistance programs as part of her 2024 State of the State.

Ms. Hochul aims to introduce legislation that would curb hospitals’ ability to sue patients earning less than 400% of the federal poverty level ($120,000 for a family of four). 

The legislation would also expand hospital financial assistance programs for low-income New Yorkers, limit the size of monthly payments and interest charged for medical debt, among other protections to improve access to financial assistance and mitigate the effects of medical debt.

“More than 700,000 New Yorkers have medical debt in collections. Individuals with medical debt are less likely to seek necessary medical care and report being forced to cut back on critical social determinants of health, including food, heat, and rent,” Ms. Hochul’s office said in a Jan. 2 news release. “As a result, substantial debt levels threaten not only the financial stability of many individuals and families, but also undermine the state’s commitment to improving health equity and health outcomes.”

The governor also aims to eliminate insulin cost-sharing through proposed legislation and provide financial relief to New Yorkers and improve adherence to these medications. With 1.58 million New Yorkers diagnosed with diabetes, Ms. Hochul’s office estimates this initiative will save about $14 million in 2025 alone. 

“Too many New Yorkers today must overextend their finances to afford critical healthcare, like insulin, and to pay everyday expenses, like rent,” New York State Department of Financial Services Superintendent Adrienne Harris said. “When an individual is forced to choose between the two, deprioritizing their health impacts their lives, their families, and ultimately increases costs across the healthcare system. The alternative is no better. Without enough cash to cover all expenses, New Yorkers have turned to buy now, pay later products, racking up debt with companies that have operated without guardrails in this state for too long.”

For-profit hospital operators strained by physician fees, payer relations in Q3

The nation’s largest for-profit hospital systems by revenue — HCA Healthcare, Community Health Systems, Tenet Healthcare and Universal Health Services — reported mixed results during the third quarter of 2023, despite announcing strong demand for patient services.

With the exception of HCA, each operator reported lower profits in the third quarter compared with the same period last year. Health systems CHS and HCA reported earnings that fell short of Wall Street expectations for revenue.

Major operators posted declining profits in the third quarter compared to the same period in 2022

Q3 net income in millions, by operator

Health SystemProfitPercent Change YOY
Community Health Systems$−91−117%
HCA Healthcare$1,80059%
Tenet Healthcare$101−23%
Universal Health Services$167−9%

Admissions rose across the board compared to the same period last year: Same facility equivalent admissions rose 4.1% at HCA , 3.7% at CHS and 0.6% at Tenet, and adjusted admissions at acute hospitals rose 6.8% at UHS. 

Although the for-profit operators began cost containment strategies earlier this year — recognizing that rising expenses, including costs of salary and wages, were pressuring hospital profitability post-pandemic — expenses also rose, with growth in salaries and benefit costs once again pressuring most operators’ revenue.

Hospital operators faced new challenges this quarter, executives said, including increased physician staffing fees and what hospital executives characterized as aggressive behavior from payers.

Hospitals highlight rising physician fees

Rising physician fees were a topic of concern on earnings calls this quarter, with executives reporting fees that were 15% to 40% higher compared with the same period last year.

Third-party staffing firms charge hospitals physician fees, a percentage of physicians’ salaries, on top of the salaries themselves. Physician fees are separate but related to contract labor costs, which plagued hospitals during the COVID-19 pandemic as they attempted to stem staffing shortages.

Hospitals typically contract specialty hospitalist roles — like anesthesiologists, radiologists and emergency department physicians — and incur associated staffing costs.

Physician fees at HCA, the country’s largest hospital chain, grew 20% year over year in the third quarter, according to CFO Bill Rutherford.

Physician fees were up by as much as 40% at UHS — making up 7.6% of total operating expenses this quarter and surpassing the company’s initial projections for the year, CEO Marc Miller said during an earnings call. Historically, physician fees accounted for about 6% of UHS’ total expenses.

Likewise, Franklin, Tennessee-based CHS attributed some of its third-quarter losses to “increased rates for outsourced medical specialists,” according to a release on the operator’s earnings.

Tenet CEO Saum Sutaria noted that physician fee expenses were up 15% year over year, but said on an earnings call that the operator had spied rising physician fees during the pandemic, and had begun efforts to contain costs — including restructuring staffing contracts and in-sourcing critical physician services.

As a result, physician fee costs at Tenet had remained “relatively flat” from the second quarter to the third quarter this year, according to the Sutaria.

Physician fee increases may be a delayed consequence of the No Surprises Act, which went into effect in January of last year, experts say.

On an earnings call, UHS CFO Steve Filton said “the industry has largely had to reset itself” in wake of the law. Tenet and CHS executives echoed the sentiment, noting that the law had disrupted staffing firms’ business models and complicated payment processes.

The No Surprises Act prevents patients who unknowingly receive out-of-network care at an in-network facility from being stuck with unexpected bills. However, the act has had unintended ripple effects, experts say.

Staffing firms and hospitals allege that the arbitration process created to resolve disputes between providers and insurers is unbalanced and incentivizes insurers to withhold reimbursement for care. In an August survey, over half of doctors reported insurers have either ignored decisions made by arbitrators or declined to pay claims in full.

In other cases, a backlog prevents claims from being adjudicated at all. Last year, the CMS found the federal arbitration process had only reached a payment determination in 15% of cases. Federal regulators have been forced to pause and restart the arbitration process multiple times in the wake of federal court decisions challenging arbitration methodology.

Although the act went into effect more than a year ago, many hospitals are just now feeling the strain, said Loren Adler, associate director at the Brookings Institute’s Schaeffer Initiative on Health Policy.

That’s because most insurers, hospitals and medical groups operate on three-year contracts, according to Adler. Staffing firms, which have struggled since the No Surprises Act was enacted, have passed on costs to hospitals as contracts come up for negotiation and insurers charge firms higher rates.

In the face of rising costs, some hospitals may opt to follow Tenet and CHS and in-source physicians — either to retain contracts with physicians who worked with firms that have folded or because the passing of the No Surprises Act makes outsourcing less attractive.

CHS hired 500 physicians from staffing firm American Physician Partners after the company collapsed in July. CFO Kevin Hammons said on an earnings call that hiring the physicians had saved CHS “approximately $4 million sequentially compared to the subsidy payments previously paid” to the staffing firm. 

However, in-sourcing may not be an effective cost containment strategy for all operators. HCA reported it was hemorrhaging money following its first-quarter majority stake purchase of staffing firm Valesco, which brought about 5,000 physicians onto its payroll. HCA CEO Sam Hazen said the system expects to lose $50 million per quarter on the venture through 2024, citing low payments as the primary issue.

Payer problems

Hospital executives also tied quarterly losses to aggressive behavior from insurers during third-quarter earnings calls.

UHS executives said payers were improperly denying high volumes of claims and disrupting payments to its hospitals, with UHS’ Miller characterizing insurers as “increasingly aggressive” during the third quarter. Though insurers had reduced their number of claims audits, denials and patient status changes during the early stages of the pandemic, payers were increasing denials and reviews, according to UHS’ Filton.

Tenet’s Sutaria said that claims denials were “excessive and inappropriate” during a third-quarter earnings call, adding that the hospital system was working to push back on the volume of claims denials.

Their number one strategy is to provide “excellent documentation” to refute denials quickly, Sutaria said.

Still, excessive claims denials can drive up administrative costs for hospitals, according to Matthew Bates, managing director at Kaufman Hall.

“That denial creates a lot more work, because now I have to deal with that bill two, three, four times to get through the denial process,” Bates said. “It starts to rapidly eat into the operating margins… [becoming] both a cashflow problem and an administrative costs burden.”

Executives across the four for-profit operators said they planned to negotiate with insurers to receive more favorable rates and limit the number of denials in subsequent quarters.

HCA’s Hazen said that it was important for HCA to maintain its in-network status with insurers “to avoid the surprise billing and that [independent dispute resolution] process,” but that it would work with its payers to get “reasonable rates” going forward.

Claim denials and payer audits are affecting the revenue cycle

https://www.healthcarefinancenews.com/news/claim-denials-and-payer-audits-are-affecting-revenue-cycle?mkt_tok=NDIwLVlOQS0yOTIAAAGQAybyM6ggpJgo3nj6rjwmb49NGUlbd0b6yUC5x8PYV_PO_M-0hvHxFayPzi7gipxN6FGBGtvC0lbz3ivr3YP9benJmUuNyUH-cD71HJ7ii7s

Claim denials are increasing, especially in Medicare Advantage, and it’s affecting hospital’s revenue cycles and patient care.

“We definitely are seeing an increase in denials,” said Sherri Liebl, executive director of Revenue Cycle, CentraCare Health, a large multispecialty system in Minnesota. CareCare has two acute care hospitals, seven Critical Access Hospitals and 30 standalone clinics, many of them in rural areas. 

CentraCare reported a positive margin this year, but in no way realizes the profits of insurers, especially the national insurers where Liebl is having the most difficulty with claims.

CentraCare’s goal in its cost to collect – not all-around denials – is to be at 2%. The health system is closer to 7% on its cost to collect. 

“The cost for our organization is exorbitant,” Lieble said.

Much of the blame for denials is falling to artificial intelligence being used in algorithms to deny claims.

UnitedHealthcare has been sued in a class action lawsuit that alleges the insurer unlawfully used an artificial intelligence algorithm to deny rehabilitative care to sick Medicare Advantage patients.

Cigna has also been sued for allegedly using algorithms to deny claims. The lawsuit claims the Cigna PXDX algorithm enables automatic denials for treatments that do not match preset criteria, evading the legally required individual physician review process.

A Cigna Healthcare spokesperson said the vast majority of claims reviewed through PXDX are automatically paid, and that the PXDX process does not involve algorithms, AI or machine learning, but a simple sorting technology that has been used for more than a decade to match up codes. Claims declined for payment via PXDX represent less than 1% of the total volume of claims, the spokesperson said.

Industry consultant Adam Hjerpe, who formerly worked for UnitedHealth Group, said there’s nothing new about payers using artificial intelligence. AI has been used for 20 years in robotic processes, statements in Excel and algorithms, he said.

Everybody is working with good intent, Hjerpe said. There are reasonable controls in place to avoid fraud and abuse.

Claims are being denied for missing information, or for the information being out of sequence, or for the claim giving an incomplete picture of the care.

“We don’t want care delayed,” he said.

Nobody wins in claims denials, said Susan Taylor, Pega’s vice president of Healthcare and Life Sciences.

While payers save money in the short-term, in the long-term, the best arrangement is to have payers and providers work together to prevent denials, said Taylor, who has worked in healthcare for more than 25 years, starting on the health system side before moving into IT. 

“There are more claims of note being denied,” Taylor said. “If you look at the ecosystem, there are a lot of opportunities for error.” 

The solution is building an agility layer to streamline workflows throughout the revenue cycle, from initial claim submission to the complex denials processing stage. 

WHY THIS MATTERS

Liebl said that denials have increased over the past two years and that there’s also been an uptick in payer audits months after payment has been made. 

Insurers want justification for why CentraCare should keep its payments, and this is especially true for Medicare Advantage claims, she said. 

One insurer said the claim didn’t meet inpatient criteria and downgraded the claim to an observation patient.

“We have a pretty good success rate as far as being able to justify we did the right care,” Liebl said.

Asked what’s driving the higher denial rates Lieble said, “Everybody wants to keep margins and expand their business. I think it comes down to profit margins, trying to keep profit margins high; we’re just trying to stay afloat.”

To combat denials and work with payers, CentraCare founded a joint operating committee to have successful partnerships. They’ve been more successful with the local Minnesota plans than the national plans, but Liebl is optimistic, she said.

“I am hopeful we can create partnerships …” she said. “Some of the denials we receive are against their payer policy. We need to be able to hold payers accountable.”

Larger health systems have a little more clout, and CentraCare is able to partner with other health systems through the Minnesota Hospital Association.

What’s being lost in all this is the patient, Liebl said. Sometimes a patient is getting a bill up to a year after a procedure.

“Sometimes the patient focus is lost when we work through some of this,” she said.

“They keep our money longer,” Liebl said. “They hold our money hostage. We have denials sitting out there for 300 days. It’s a lot of administrative burden on our part. We’ve spent a lot of money just to get the money in the door. Finally when that claim has been resolved, it’s a year later. No one wins? I think there is some winning going on one side.”

Pennsylvania health system drops Cigna

West Reading, Pa.-based Tower Health will be out of network for all Cigna Healthcare members starting Jan. 1 following a disagreement over reimbursement rates, the Reading Eagle reported Nov. 24.

The split applies to all Tower Health facilities and physicians for Cigna commercial, Medicare Advantage and behavioral health plans. Cigna said it is continuing to negotiate with Tower Health, but the health system has already begun to notify patients about the impending contract break.

“Tower Health, like other health systems, has been contending with unprecedented cost increases for personnel, supplies, equipment and medication necessary to continue providing high quality care,” a health system spokesperson told the Eagle. “Cigna has been unwilling to compensate Tower Health at reasonable payment rates.”

“We are disappointed that Tower Health is choosing to leave our network Jan. 1 unless we agree to their demands for significant rate increases that will make healthcare much more expensive for the people we serve,” a Cigna spokesperson told the Eagle. “It’s important to understand who pays the bills: any increase in cost of care is paid directly by local employers, their employees and families.”

American Hospital Association: Medicare Advantage denials jump 56%

Medicare Advantage and commercial claims denials have spiked across the country, leaving hospitals increasingly financially strapped, according to research published Nov. 17 by the American Hospital Association and Syntellis. 

The report analyzed data from a national sample of 1,300 hospitals and health systems. From January 2022 to July 2023, revenue reductions related to Medicare Advantage denials increased 55.7% for the median hospital. During the same period, denial-related revenue reductions rose 20.2% for commercial plans. For denials relative to net patient service revenue for the median hospital, Medicare Advantage plans saw an increase of 63.3% and commercial plans rose 20%.

“[Hospitals] must take larger revenue reductions to account for those lost reimbursements from commercial payers and Medicare Advantage plans, which cover more than 31 million Americans and make up about half of all Medicare beneficiaries,” the report said. “The challenges will only worsen as Medicare Advantage enrollment continues to grow.”

In November 2022, an AHA survey found that half of hospitals and health systems reported having more than $100 million in unpaid claims that were more than 6 months old. As of June 2023, health systems had a median of 124 days cash on hand, down from 173 days in January 2022. 

The new data coincides with recent reporting from Becker’s about hospitals across the country that have ended some or all Medicare Advantage contracts. The reasons behind contract terminations vary by system and by payer offering the plan. Some systems have cited steep losses amid excessive prior authorization denial rates and slow payments from insurers. Others have noted that most MA carriers have faced allegations of billing fraud from the federal government and are being probed by lawmakers over their high denial rates.

“It’s become a game of delay, deny and not pay,” Chris Van Gorder, president and CEO of San Diego-based Scripps Health, told Becker’s in September.

According to data shared with Becker’s by FTI Consulting, among the 64 contract disputes reported in the media this year through Sept. 30, 37 involved Medicare Advantage plans, and 10 disputes exclusively involved MA plans. In the third quarter alone, 15 disputes involved MA plans, compared to seven in the third quarter of 2022, a 115% increase year over year.