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Authorization 2018: New Billing and RFA Deadlines

January 12, 2018 by Catherine Montgomery

5 day deadline for fast-track RFAThe new “fast-track” automatic authorization process took effect on January 1, 2018. Under certain circumstances, some providers may provide “automatically” authorized treatment without submitting a prospective Request for Authorization (RFA). Of course, this new process is subject to new rules and conditions — including new deadlines for submitting an RFA and for submitting the corresponding billing.

Today, we explore the timeframe requirements for all fast-tracked treatments. We're also hosting a free webinar on the fast-track process on Tuesday, February 6. 

New RFA Timeframe Requirements

In our last fast-track entry, we explained the 6 qualifying conditions that make a given treatment eligible for automatic authorization. We also promised to explain why this new authorization isn’t as “automatic” as the term implies. In fact, providers still need to submit a compliant RFA, even for fast-tracked authorized treatments.

What’s changed is when the RFA is due.

The new Labor Code § 4610, as revised by Senate Bill 1160, lays out the timeframe requirements that took effect on January 1. According to the code, providers must submit a compliant RFA within 5 days of the date of service. Providers must also continue to submit a Doctor’s First Report of Occupational Injury or Illness (DLSR 5021) within 5 days of treatment.

The regulations do not specify, but presumably the RFA is considered a retrospective RFA where the treatment is automatically authorized. If the Division of Workers’ Compensation promulgates further regulations to clarify this (for the sake of response timeline requirements), we will let our readers know.

New 30-Day Billing Deadline

30 day billing deadline for fast-tracked treatmentsCrucially, the revised § 4610 also mandates a new, shorter billing deadline for fast-tracked authorized treatments. Providers must submit their original bills within 30 days of any automatically authorized treatment. That is a much, much shorter timeframe than bills for conventionally authorized treatments, for which bills must be submitted within 12 months.

The regulations do not specify that bills submitted after 30 days are void, but we strongly suggest providers adhere to this requirement.

For quick and easy reference regarding fast-track automatic authorization timeframe requirements, use this chart:



Submit DLSR 5021

Within 5 days of treatment

Submit RFA

Within 5 days of treatment

Submit Original Bill

Within 30 days of treatment

As we move forward into 2018, we’ll keep readers up to speed on every development in the implementation of this new process. As fast-track automatic authorization takes effect on the ground, we’ll be here to help guide work comp professionals, as always. 

Sign up below for our free, comprehensive webinar on fast-track automatic authorization, where we'll review everything there is to know on authorization in 2018.



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