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Berry E - What makes HRI's effort different from the kind of payback attempts physicians might be accustomed to is HRI's claim - not yet legally countered - that plans operating under ERISA law aren't limited by the constraints many states put on insurers, particularly in how far back in time they can go to reclaim payment. Like health plans, HRI identifies physicians it believes are above the norm in the number of high-level codes they submit and targets them for recoupments. Unlike health plans, however, HRI does not analyze individual medical records along with the claims.

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