No Surprises Act Protects Patients from Surprise Bills

In the past, if consumers have health coverage and receive care from an out-of-network provider, their health plans usually won’t cover the entire out-of-network cost. This could leave them with higher costs than if they’d been seen by an in-network provider.

This has been especially common in an emergency situation, where consumers might not be able to choose the provider, and even if they go to an in-network hospital, they might receive care from out-of-network providers at that facility, such as radiologists, emergency physicians, anesthesiologists, etc. Often, out-of-network providers will bill for the difference between their charges and the amount paid by the consumer’s health plan. This is known as balance billing, resulting in what’s become known as a surprise bill.

Introducing the No Surprises Act

As of January 1, 2022, the “No Surprises Act,” enacted by Congress in 2020, reduces patients out-of-pocket costs for certain services. This law is designed to protect consumers against most surprise bills when receiving emergency care or non-emergency care from out-of-network providers at “in-network” facilities. It also includes protections for patients requiring out-of-network air ambulance services.

CommonSpirit Getting Ready to Comply

CommonSpirit is well-positioned to comply with the No Surprises Act. A cross-functional team was brought together soon after the bill was enacted and began preparing for its effects. That team includes acute and ambulatory partners across Payor Strategy and Relationships, Revenue Cycle, Legal and others across the ministry. It is led by Tammy Wilcox, System Senior Vice President of Payer Strategy and Relationships; Danielle Weber, System Senior Vice President of Revenue Cycle; and Larry Blumenthal, Vice President, Finance for Physician Enterprise. Despite limited federal guidance, the teams have updated an array of policies and procedures, including:

  • How we work with insurance companies regarding the amount CommonSpirit Health facilities and providers are reimbursed for services provided to patients whose services are covered by the No Surprises Act;
  • How we provide estimates of costs to uninsured patients who schedule or are shopping for services;
  • And many other activities.

As well, our preparations include posting patient notifications and training and providing resources for acute and ambulatory revenue cycle employees/partners as well as many other functions. 

This is a complex law and the implementing regulations leave many questions still to be answered. However, enforcement will be conducted by federal and state agencies in the near future and allows for consumers to file complaints with regulators directly.

We Are Committed to Fair Billing Practices

CommonSpirit and our founding organizations have long been committed to helping patients understand their health care costs. In addition to tools that are already in place, like cost estimate tools that are available on CommonSpirit Health hospitals’ websites, CommonSpirit has signed on to the American Hospital Association’s Patient Billing Guidelines reaffirming  our long standing commitment to fair billing practices.  It emphasizes that we: treat all people equitably, with dignity, respect and compassion; serve the emergency health care needs of all, regardless of ability to pay; and assist patients who cannot pay for part or all of the care they receive.

Questions?

If you have questions about how CommonSpirit will comply with the No Surprises Act, please contact [email protected]. For general information about the act, visit this website.