If the CRAs verify the med collection and the CA does not send validation, the Alt Med DV letter would be in the next round of letters. You really need to prove a business relationship exists between the OC and CA, validation from the CA would prove that. Another thing to pay close attention to is what happens after the CRAs receive the pre-HIPAA disputes. The CRAs MUST mark the collection as in dispute, or disputed and verified. If they don't, then its time to step outside of the HIPAA process and file a complaint against the CRA(s) with the FTC for not properly investigating and for refusing to delete a paid, invalidation collection.
