Overall I think the proposed changes are positive. With respect to the expansion of ODG I believe ODG, while not perfect, is a terrific guideline. ODG is comprehensive, covering all 65,000 ICD-10 diagnostic codes and 11,000 CPT procedure codes. ODG is easy to navigate, with all recommendations linked to supporting medical evidence, which has been ranked, highlighted, and indexed. And ODG is continuously updated. I even like how the date of the version I’m looking at is always clearly visible. While we do not exclusively endorse any particular guideline, be it ODG, ACOEM, the Colorado Guidelines, etc., it’s my experience that states’ adopting ODG generally get good results by doing so.
With respect to a mandatory RFA form, I believe this is a good idea. Sometimes we receive treatment requests from providers that lack key information. Missing information usually involves the injured worker, the provider’s identity, the employer or payer’s identification, or details about the requested treatment. I’ve noticed over the years that the treatment request process goes smoother in states that have a standardized RFA form and require providers and carriers use it.
The third major change shortens the current 10 business day turnaround time for prospective UR to 7 business days. While this does shorten the window in which to process a request, I believe 7 days is plenty of time for most requests. This is especially true when all the needed information is correctly printed on the RFA (see above). Keep in mind that for many years California has used a 5 business day turnaround time, and Texas allows just 3 business days. So I believe the Arizona 7 day timeframe is, by comparison, still pretty generous.
I believe Arizona is headed in the right direction with respect to the three proposed UR changes. We will continue to closely monitor Arizona in case there are any additional subtle rule changes that require us to alter our UR process.