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May 06, 2022   
Health Law Weekly

Major Issues for Compliant Health Care Billing Practices Under the No Surprises Act

This Featured Article is contributed by AHLA’s In-House Counsel Practice Group.
  • May 06, 2022
  • Michael Kolber , Manatt Phelps & Phillips LLP
Stethoscope, money, and calculator

The federal No Surprises Act (NSA), which became effective January 1, 2022, represents a massive change to health care patient financial practices, even in situations that do not involve “surprise” medical bills. The implementation challenges are made even more complicated by the fact that federal regulators have issued no guidance on how to apply some statutory provisions and, for others, have rolled out guidance at nearly the last minute. What should health care provider and facilities, and their attorneys, do now? Here are three areas to focus on: updating (or creating) procedures for providing estimates to self-pay or uninsured patients; developing workflows to obtain a patient’s consent to pay full billed charges for out-of-network care when permitted; and planning for arbitrating health plan out-of-network reimbursement.


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