Conflicts of interest policy

Purpose and scope

A company that argues payment disputes for providers sits between three parties with money at stake: the provider, the payer and the arbitrator. Buyers of these services have learned to ask who else is in the money flow. This policy is our answer. It sets out how Revise Medical, LLC is paid, the relationships we refuse, and what we do when a conflict appears.

It applies to Revise Medical, LLC, its members, managers and officers, every employee, and every contractor who works on client disputes. It covers open negotiation, federal and state independent dispute resolution (IDR), and the collection of awards. Where a client agreement sets a stricter rule, the agreement wins.

Our role

We act as the provider’s authorized representative. Every filing is made in the provider’s name, under a written authorization the provider signs. The provider keeps the decisions that matter: which claims to dispute, which settlement offers to accept, and whether to escalate.

• We are never an IDR entity. We do not decide disputes, we have not applied for certification, and we will not.
• We do not act for payers. We do not represent health plans, issuers or third-party administrators in payment disputes, and we would never act for both sides of the same dispute.
• We are not a law firm. We do not give legal advice. When a dispute needs a lawyer, the client engages counsel directly.

How we are paid

Our fee is 19% of the cash that reaches the client’s account on disputes we work. The payment the client had before open negotiation is never counted. An award that is never paid earns us nothing. On the engine tier, clients pay a flat price per claim and per dispute instead, so our pay does not depend on the outcome at all.

• We front the fees. We pay the federal administrative fee and the IDR entity fee from our own capital and recoup them from the award on the monthly statement.
• Ineligible filings are our cost. If an IDR entity rules a dispute we filed ineligible, we absorb the fees. Our ineligibility rate is printed on every statement.
• We never hold client funds. Payers pay the provider into the provider’s own account. We do not run an operating account in a client’s name and do not route awards through any related party.

Where our interests could differ from yours

Being paid on cash collected lines our interest up with yours on most questions: we want the largest payment, paid soonest. It does not line up on every question, and we would rather name the gaps than leave you to find them.

• Settle or go to IDR. Because we front IDR fees, a settlement in open negotiation saves us money even when IDR would likely pay you more. Every settlement offer above or below your approval threshold goes to you, and we never accept one without your authority.
• Which disputes to file. Because ineligible filings cost us, we may advise against a borderline dispute. We tell you why, and you can direct us to file it.
• Where our attention goes. Larger claims pay us more. Every eligible dispute is worked to the same deadlines, and the portal shows each one so you can check.

Relationships we do not have

These are standing commitments, not a list of exceptions.

1. No ties to IDR entities. Revise Medical, LLC, its members, its managers and its officers hold no ownership interest in any certified IDR entity. We accept no payment, discount, rebate or service from one, and we do not share staff with one.
2. No ties to payers. We hold no ownership interest in any health plan, issuer or third-party administrator, and we take no payer-side engagement of any kind.
3. No affiliates in the money flow. No related party processes payments, holds funds or bills fees on a client’s disputes.
4. No referral fees that steer a client. We take nothing from a law firm, IDR entity or other vendor we recommend to a client. Clients contract with counsel directly. Where a billing company or other partner refers a client to us, the arrangement and who pays it are stated in that client’s agreement before signing.
5. Investor disclosure. We ask every investor with a board seat or more than 5% of our equity to tell us of any interest in a certified IDR entity or a health plan. Any such interest will be listed on this page.

How we screen for conflicts

We keep a conflicts register and check it at two points.

• At onboarding. The client tells us its owners, affiliates, tax IDs and NPIs, and any relationship it or its clinicians have with a health plan or a certified IDR entity (for example, a physician who reviews cases for one). We check these against our own register of company, staff and investor relationships before we sign.
• Before each dispute. We check the payer and plan against the client’s disclosed affiliates, and the IDR entity we propose against both registers. We record why we chose that entity: its decision history in the CMS public-use files and our own determinations, its fees and its timeliness. Nothing an IDR entity pays or offers has any part in that choice.
• When something changes. A new client, partner, investor, hire or change of ownership at an IDR entity triggers a fresh check. We review the register every quarter.

IDR entity conflicts under federal rules

The No Surprises Act regulations bar a certified IDR entity from deciding a dispute in which it has a conflict of interest. A conflict includes a material familial, financial or professional relationship with a party, and a material financial relationship means an interest worth more than 5% of the entity’s total annual revenue or income. Entities must screen for conflicts as a condition of certification, and the entity selected for a dispute must attest that it has none before the selection is final (45 CFR 149.510, paragraphs (a)(2), (c)(1) and (e)).

How we use those rules on the client’s behalf:

• Selection. We name a preferred IDR entity in the notice of initiation only after the screening above.
• Objection. If the payer proposes a different entity and we find a conflict with it, we object within the deadline and explain the conflict, as the rules provide. If the parties cannot agree, the Departments select the entity.
• After assignment. If we learn of a conflict once an entity is assigned, we tell the client, raise it with the entity and the Departments, and with the client’s consent consider a petition to deny or revoke the entity’s certification under paragraph (e)(5).

Employees and contractors

• Disclosure on joining. Every employee and contractor discloses any financial interest in, or work in the past year for, a certified IDR entity, a health plan, or a client. They sign an attestation again every year and update it within 30 days of any change.
• Recusal. No one works on a dispute involving an organization they worked for in the past 12 months, or a claim they handled personally at a payer.
• Gifts. We accept nothing of value from a certified IDR entity or its staff. From payers, vendors and partners, we accept no cash or cash equivalents and nothing worth more than $100 a year from any one source. Every gift is logged.
• Outside work. Staff may not work for an IDR entity, a payer or a competing dispute vendor while employed here without written approval.

Client data stays separate

Each client’s data sits in its own organization space, isolated at the database row level, as described on our security page. We do not use one client’s claims, contracts, rates or documents in another client’s dispute, and we share nothing with a payer or IDR entity beyond what a filing for that client requires. Our award model learns from the CMS public-use files and from our own determinations only as de-identified statistics, to the extent each client agreement allows.

When a conflict arises

If screening or anyone on our team finds an actual or potential conflict, we:

1. Pause the affected work, unless pausing would miss a federal or state deadline.
2. Tell the affected client in writing within five business days: what the conflict is and what we propose.
3. Proceed only with the client’s written consent, with safeguards such as a different team, or decline the work and help move it to another representative.
4. Record the conflict and the outcome in the register.

If two clients’ interests diverge on a matter we handle, we tell both and act only with each one’s written consent. Where consent would not cure the conflict, we step aside.

Reporting a concern

Anyone, inside or outside the company, can report a concern about a conflict to security@revise-medical.com with “Conflict” in the subject line. It reaches our compliance lead and is answered within ten business days. We do not retaliate against anyone who raises a concern in good faith, and a report about a manager goes to someone outside that manager’s line.

Review and changes

We review this policy at least once a year and whenever the business changes in a way it covers: a new product, a new type of partner, or a new investor. Any change is published here with its date. If a change loosens a commitment, every client is told in writing at least 30 days before it takes effect.