The first regulation implementing the No Surprises Act is out. This law protects patients from most surprise bills starting in 2022 cms.gov/files/document…
In the standard notice and consent form for Surprise Billing Protections, if patients don't have sign, plans are required to help patients find an alternate in-network provider or work out a payment agreement with the out-of-network provider.
The Surprise Billing IFR 1 includes:
-patient disclosures letting them know of their protections
-patient notice and consent requirements for out-of-network charges
-out-of-network payment, including patient cost-sharing, based on all-payer model agreements or QPA
The surprise billing IFR defines what's considered emergency and warns that plans can't retroactively (based on final diagnosis codes) decide an emergency visit was not urgent.
The Biden Administration is expected to publish the first implementing rule of the No Surprises Act by tomorrow July 1. In this thread, I’ll list 10 key questions to look out for in the interim final rules.🧵1/12
Question 1 on No Surprises Act: How will patients be notified of surprise medical bill protections? Will patients know how to dispute unexpected bills? Patients will need to be informed of what to expect and how to dispute unexpected bills. (2/12)
Q2 on No Surprises Act: How will a federal consumer complaints system work? The federal government is required to establish a national consumer complaints system, something that does not currently exist within the agency. What actions will CMS take for complaints? (3/12)
The Biden Admin is proposing extending open enrollment by 30 days and creating a monthly special enrollment period (SEP) for low-income people with incomes up to 150% of poverty.
The rule contemplates risk of adverse selection with a monthly SEP for low-income people in ACA Marketplaces. Low-income people are more price sensitive but this group is eligible for free-premium plans, which may dampen the adverse selection risk.