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No Surprises Act: How to Ensure Compliance

In 2021, Center for Medicare & Medicaid Services (CMS) issued the No Surprises Act that went into effect on January 1, 2022. This Act provides Federal protections against surprise billing and limits out-of-network cost sharing under many of the circumstances in which surprise bills arise.

Prior to this Act, individuals could be “balance billed” for items or services that they received from an out-of-network provider or health care facility in many states. “Balance billing” occurs when an out-of-network provider or health care facility bills an individual for the difference between the billed charge and the amount that the health plan paid. As a result of the No Surprises Act, individuals are protected from getting “balance billed” for emergent and some non-emergent services from out-of-network providers.

The No Surprises Act also outlines a process for which uninsured or self-pay individuals are to be provided a good faith estimate of their estimated financial responsibility for any item or service that is reasonably expected to be provided in conjunction with their scheduled care.

No Surprises Act and Your Organization

Providers and health care facilities (such as a hospital, critical access hospital, ambulatory surgery center, rural health clinic, federally qualified health center, laboratory, or imaging center) are required to comply with the No Surprises Act regulations that went into effect on January 1, 2022. Disclosures, notices, consent forms, and good faith estimates must be provided to individuals as specified by the Act.

Some of the requirements include:

  • Disclosures that describe patient protections under the No Surprises Act must be posted and provided.
  • Providers and health care facilities must issue notice and consent forms to balance bill individuals with out-of-network coverage for certain services.
  • Uninsured or self-pay individuals must be provided a good faith estimate of medical services and/or items upon request. The good faith estimate should include the expected charges for scheduled health care services.
  • Providers and health care facilities can participate in an independent dispute resolution process in instances for which an agreed-upon payment amount cannot be reached with an out-of-network health plan.

Blue’s No Surprises Act Resource

We have developed policies, procedures, and process implementation strategies that are necessary for compliance. Additionally, we can conduct training sessions to educate pertinent staff to ensure a successful implementation.

Below you can download the handout to learn more about how the No Surprises Act will affect your organization.



Contact Us

If your organization has any questions surrounding the No Surprises Act, reach out to your local Blue & Co. Advisor or Kyle Myers using the contact information below.

Kyle Myers, Manager
317.275.7447

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