If you’re fully-insured your NSA IDR four-year tail is covered. If you’re self-funded it isn’t and accrued risk can be significant.
Balance bills subject to the NSA IDR process are tied to the date of service. The responsible payer is the insurer that provided coverage on the date of service, not any succeeding insurer in place when the IDR is filed or resolved.
If the plan was fully-insured at the time of service the plan sponsor is indemnified by the carrier in place at the time of service, his tail is covered. However, if the plan was self-funded at the time of service the plan sponsor remains at risk up to and until the statute of limitations ends (4 years in Texas).
A self-funded plan sponsor may get a letter like this….“Hi, you owe us $2.6 million for balance bills accrued over the past three years. Let’s have an IDR party!”
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