3 Years Later: Lessons Learned from the No Surprises Act

The No Surprises Act went into effect in 2022, forcing major changes to workflows throughout revenue cycle operations. Three years later, what have health systems learned and how are they faring?

The No Surprises Act went into effect in 2022, creating many challenges for healthcare revenue cycle leaders.

Amanda Bessicks has worked alongside them to ensure as smooth an implementation as possible.

The executive director of government and vendor relations at Baptist Health in Northeast Florida, Bessicks has helped to coordinate between internal and external stakeholders, including lawmakers, to meet the challenges presented by the No Surprises Act.

Three years later, she shares what she learned.

Dealing with new challenges

The volume of work required to comply with the No Surprises Act was perhaps the most difficult obstacle to overcome, according to Bessicks. As Baptist Health began investigating areas for improvement, they noticed that there were gaps.

For instance, new requirements that providers must provide good faith estimates to uninsured and self-pay patients meant the health system needed to build out an existing estimator tool with processes to ensure all relevant procedure codes were being captured.

The No Surprises Act also introduced the IDR process to manage provider-payer disputes. The federal portal that facilitates disputes over out-of-network reimbursement has collected far more reports than anticipated, causing lengthy delays for reimbursement – or no reimbursement at all.

"At the outset, we really didn't how it would work," Bessicks said. "We now have a good understanding of how the IDR process works, but it's a very, very slow process, and so you're not getting claims resolved very quickly."

The value of coordination

When public policies shift, "bringing together the right stakeholders" is key to ensuring a cohesive response, according to Bessicks. However, it's not always clear who the right stakeholders are

When the No Surprises Act was signed into law, there was some clarity about how it would affect some revenue cycle processes, like scheduling and billing. But there was less certainty around what Bessicks calls the "ancillary impacts."

The government and vendor relations team at Baptist Health found themselves working with some unexpected allies. For instance, inefficiencies in the IDR process and confusion around billing for reference-based pricing plans led Bessicks and her team to reach out to employers.

They wanted to know whether the employers realized what health plans were paying for services provided to their employees.

"A lot of the time, they have no idea," Bessicks said.

By building rapport with and educating employers who are purchasing health coverage, there are opportunities to create allies who can also influence policymakers on laws like the No Surprises Act or their state-level equivalents.

For revenue cycle leaders who want to become more involved in policymaking processes, Bessicks recommends working with their health systems' government relations teams. These teams have already built relationships with lawmakers and developed communications channels to deliver information to them.

"You want to ensure that there's one voice coming from the organization," Bessicks said.