Key Provisions
- Patient Protections:
- Bans surprise bills for emergency services at any facility
- Prohibits out-of-network charges for ancillary services at in-network facilities
- Requires good faith cost estimates for uninsured/self-pay patients
Provider Requirements
✔ Must provide clear written notice of network status
✔ Required to submit timely billing information to insurers
✔ Must participate in independent dispute resolution for payment disagreements
Good Faith Estimate Rules
• Applies to uninsured/self-pay patients
• Must be provided within 3 business days of scheduling
• Includes expected charges from all participating providers
Compliance Deadlines
- Emergency services: Immediate compliance required
- Good Faith Estimates: Phased implementation since 2022
- Dispute resolution: Quarterly reporting requirements
Action Items for Practices
- Update billing software to include NSA requirements
- Train staff on new disclosure forms
- Establish internal audit procedures
- Document all patient communications
Penalties for Non-Compliance
- Up to $10,000 per violation
- Possible exclusion from federal programs
- Mandatory refunds to patients
