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Temporary COVID-19 Policy Changes

During this COVID-19 emergency, we’ve made temporary changes related to claims, coding, enrollment and other policies that takes precedence over information in our current PAMs.

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No Surprises Act, Consolidated Appropriations Act, 2021

Learn what we’re doing to meet the Consolidated Appropriations Act, 2021 (CAA) requirements while supporting the needs of affected members and providers. The scope and effective date of these requirements are based on the provisions as we currently understand them and may change with future guidance from the government.

Surprise Billing Protections

Starting Jan. 1, 2022, members enrolled in commercial health care coverage offered or administered by BlueCross will have new protections from unexpected medical bills for certain emergency and ancillary services from out-of-network providers. They’ll also have new protections for covered services provided by out-of-network providers at an in-network facility.  (These provisions do not apply to individuals enrolled in Medicare Advantage Plans or Medicaid managed care plans, such as BlueCare.)

Members shouldn’t get surprise medical bills when they get out-of-network care for:

  • Emergency services at an out-of-network hospital ER or freestanding ER
  • Non-emergency, ancillary services from an out-of-network provider furnished at an in-network facility
    • These can include anesthesia, pathology, radiology, laboratory, neonatology, assistant surgeon, hospitalist and intensivist services.
  • Non-emergency services furnished by non-ancillary providers unless the member receives notice of, and provides consent to, treatment by the provider and balance billing.
  • Out-of-network air ambulance transport if the services would have been covered if provided by an in-network air ambulance provider.

Please consult your legal representative for a complete list of the services that are protected.

To submit additional claims information electronically, follow the Supplemental EDI Information guidelines and complete the PWK Fax Cover Sheet.

Balance Billing Restrictions


The CAA prohibits out-of-network providers from balance billing members for emergency services. Regarding non-emergency services, out-of-network providers furnishing certain services at in-network facilities can balance bill, but only after a member executes the required consent form. Not all services are eligible for balance billing after obtaining a member’s consent, such as, but not limited to, anesthesia, pathology, radiology, laboratory, neonatology, and also assistant surgeon, hospitalist and intensivist services.

The U.S. Department of Health and Human Services (HHS) has issued additional regulations and information for providers regarding required notice and consent documents, along with instructions on how to provide these documents to patients.

Information we’re required to share with out-of-network providers when we adjudicate a claim and the provider is not permitted to balance bill:

If you’re an out-of-network provider or facility, as applicable, and provided emergency services, non-emergency services at an in-network facility without notice and consent, or covered air ambulance services, the member’s cost-sharing is calculated based on the “recognized amount.” Federal regulations define the recognized amount; in Tennessee, the recognized amount is the lesser of “qualifying payment amount” (or QPA) and the provider’s billed amount.

When the recognized amount is the QPA, federal law requires us to provide you with certain information about the QPA. Some of it is included on your remittance advice, like the actual QPA for the item or service; additional information is set forth below.

Additional information about the QPA:

  • The QPA is defined in federal law as the 2019 median contracted rate for an item or service furnished by a similar provider or facility in the same insurance market, increased by the applicable percentage determined by the federal government.
  • BlueCross determines the QPA in accordance with federal law.

Additional information about payments:

If you’re not satisfied with your payment from us, you can begin the open negotiation period provided under federal law. This process is specific to situations under the law where BlueCross pays an out-of-network provider according to the CAA and the out-of-network provider is prohibited from balance billing the member.

If you wish to initiate a 30-business-day open negotiation period for purposes of determining the amount of total payment for services provided to a member, you must complete and email the federally required Open Negotiation Notice form to BlueCross at In addition, please return the BlueCross Open Negotiation Notice Supplemental Information Form, so we have everything we need to review your request. Links to these forms can be found below. If you have questions about this process, please call Provider Service at 1-800-924-7141 1-800-924-7141.

If you’re not satisfied with the payment amount at the end of the open negotiation period, you may initiate the independent dispute resolution process within four business days after the end of the open negotiation period.

Here are the links to the forms to initiate the 30-business-day open negotiation period:

If you need additional help, please call Provider Service at 1-800-924-7141 1-800-924-7141.

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Provider Stability Act

In keeping with the Provider Stability Act (PSA), we're giving you advance notice when we make changes to our Commercial policies, procedures and fee schedules. Here's more information about the law and how we're providing your updates.

Provider Stability Act Details
Changes to Manuals, Reimbursement Rules or Policies

When an insurer makes changes to a Commercial provider manual, reimbursement rule or policy, the insurer must disclose or identify that information at least 60 days before the change takes effect. Here’s how we’ll communicate these changes to you:

  • We’ll use bold print or a larger font to identify changes in our Provider Manuals.
  • We’ll send you a separate communication about reimbursement rule and policy changes and their effective dates.

Changes to Fee Schedules

Insurers must give you at least 90 days’ notice about any Commercial fee schedule changes and effective dates. We’ll send the required notice to your dedicated email address or as otherwise mentioned in your BlueCross contract. We cannot make Commercial fee schedule changes more than once in a 12-month period. However, a health insurance carrier and a hospital may agree to changes in writing.

Exceptions include changes to your:

  • Fee schedule effected by the state or federal government
  • Reimbursement for drugs, immunizations, injectables, supplies or devices if you and the health insurance carrier or PBM agreed reimbursement will be based on an index not established by the health insurance carrier
  • Reimbursement for drugs, immunizations, injectables, supplies, or devices if the provider and the carrier or PBM have previously agreed to reimbursement based on maximum allowable cost pricing
  • CPT®, HCPCS, ICD or other code sets recognized or used by CMS that a health insurance carrier used in creating your fee schedule
  • Revenue codes as established by the National Uniform Billing Committee (NUBC)
  • Fee schedule due to one or more of the following if previously agreed to in a provider’s agreement with a health insurance carrier:
    • Payments made to you are based on values or quality measures explicitly described in your agreement and intended to improve the quality of care provided to our members
    • Escalator or de-escalator clauses
    • Provisions that require adjustments to payment due to population health management performance or results
    • Tennessee Healthcare Innovation Initiative (THCII)

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Find our upcoming PAM, see newly approved policies and guidelines, and offer feedback on developing policies and updates.

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All Blue Provider Workshops

We’re based right here in Tennessee and we host the All Blue Workshops to better partner with you as you provide care for our neighbors covered by a BlueCross plan.

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