The No Surprises Act (NSA) is intended to protect patients from unexpected medical bills and is best known for its restrictions on balance billing. But compliance experts quoted by Healthcare Dive said lesser-known requirements in the law may surprise some healthcare providers and be difficult to implement. For example, a broad range of providers are required to produce a “good faith estimate” of expected costs to uninsured and self-pay patients when they schedule an item or service or upon request, the story notes.
Gadani, an associate in McGuireWoods’ Austin, Texas office, said some providers, such as dermatology practices, may not realize they are subject to this requirement if they are not subject to the law’s better-known balance billing restrictions. But those practices would be subject to providing good-faith estimates under the new law, she said.
Because of the detailed requirements and nuances of the law, Gadani noted that “The No Surprises Act is a lot more convoluted than you initially realize.”
Gadani and members of the firm’s healthcare practice have released two legal alerts on developments related to the NSA. An April 15, 2022, alert outlines new guidance from the Centers for Medicare & Medicaid Services related to the balance billing prohibition and good faith estimate requirement and the launch of the independent dispute resolution (IDR) portal. A Feb. 25, 2022, alert analyzed a federal court ruling striking down a portion of an interim final rule related to the IDR process.