Trilatic is the trade name of Ripplarity Inc, a Delaware corporation. This page sets out what independence a dispute-resolution entity must hold under 45 CFR 149.510(a)(2), what the rule actually tests, and the controls that apply to every activity carried on under the same legal entity.
Ripplarity Inc carries on dispute-resolution work under the Trilatic name and offers no product to providers, facilities, plans, issuers, their administrators or trade associations.
45 CFR 149.510(a)(2)(iv) has two parts, and they are different in kind.
Paragraphs (A) through (C) are status tests. An entity is barred if it is, or is affiliated with, a group health plan, a health insurance issuer, a carrier, a provider, a facility, a provider of air ambulance services, or a professional or trade association of any of those. This is an ongoing bar on what the entity is, with no lookback limit.
Paragraph (D) is a relationship test applied dispute by dispute. Personnel assigned to a determination may not hold a material familial, financial, or professional relationship with a party to that dispute, tested over the year before assignment. A material financial relationship is one worth more than five percent of the subject's total annual revenue. A relationship of that kind is cured by declining the dispute and being re-selected, not by disqualification of the entity.
Every commercial relationship the entity holds is recorded and screened under (D) as described below.
One counterparty ledger. Trilatic keeps a single counterparty ledger. Every organisation that pays for a Trilatic service is entered on it before delivery, with the date, the role, and the amount, and the entity's other commercial counterparties are entered as they are engaged. The conflict engine screens every dispute against that ledger before a reviewer is assigned. A match is never a bare yes or no: the screen records which party matched, on what basis, and whether the relationship is material, and the record is appended to the audit chain whether or not it trips.
One-time tools, no ongoing relationship. The self-serve pre-check tools on this site may be bought by any organisation not on the refusal list, including initiating and non-initiating parties. Every purchaser is recorded on the counterparty ledger before anything is delivered, and any dispute in which a purchaser is a party is declined for the 365-day lookback that applies to every other counterparty. No subscription, advice, or ongoing relationship is offered to any party. The research report ranks nothing and names no entity as better or worse than another.
Recusal, with a one-year lookback. Where a counterparty on the ledger appears as a party to a dispute, the entity declines that dispute within the attestation window and the dispute is re-selected. Personnel are screened the same way, and every screen, including a clean one, is retained.
Fixed fees, no contingency. Nothing Trilatic sells is priced on the outcome of any dispute, and reviewer compensation is set per assignment or per hour before the assignment is made. Reviewer fees are paid from the operating account and never from the account that holds parties' dispute fees.
Separate systems. The dispute engine runs as its own service, and dispute records are held in stores that only the dispute engine reads.
No provider-facing or payer-facing surface. Trilatic offers no product to providers, facilities, plans, or issuers, and publishes no rankings of payers or providers. That remains the position while the entity seeks or holds certification.
Questions about independence or a possible conflict: compliance@trilatic.com, acknowledged within one business day. Concerns may also be raised directly with the Departments at FederalIDRQuestions@cms.hhs.gov.