Questions and Concerns Related to Implementing the Federal No Surprises Act?

June 24, 2022

The American Medical Association (AMA) is working with the Centers for Medicare and Medicaid Services (CMS) to encourage more physician outreach and education on the implementation of the federal No Surprises Act (NSA). If you have questions or implementation concerns about any of the specific requirements of the federal NSA, please send them to ISMS via email as soon as possible. Your feedback will be shared with the AMA and CMS.

The following are some general areas we are monitoring, but we would welcome other perspectives:

  • Good Faith Estimate requirements for uninsured or self-pay patients;
  • Surprise billing prohibitions;
  • Notice and Consent requirements;
  • NSA enforcement; and
  • The payment process under the NSA, including the initial payment, open negotiations, and Independent Dispute Resolution process.

CMS indicates that your comments and questions will be used to help shape content for upcoming informational webinars.

For an overview of the No Surprises Act, view ISMS’ Issue Brief, which has been recently updated to reflect the opening of the federal independent dispute resolution (IDR) process portal and recent changes to Illinois law.

Questions? Please contact the ISMS Health Policy Research and Advocacy team by email.

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