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No Surprises Act Temperature Check with Revenue Cycle Leaders

Analysis  |  By Alexandra Wilson Pecci  
   February 08, 2022

HealthLeaders checked in with revenue cycle leaders and experts across the country to hear about the first few weeks of this landmark rule.

We're just over a month into the implementation of the No Surprises Act (NSA), which protects patients from balance billing but still has a lot of controversy surrounding it, namely around the arbitration method, which providers say unfairly favors payers.

Still implementation and compliance are underway, says Becky Greenfield, a partner with Wolfe Pincavage.

"Our clients are working diligently to comply with all components of the NSA, developing work groups spanning across patient accounts, legal, revenue integrity, managed care, IT, and other departments to identify operational and technical areas that need to be updated to achieve compliance," she says via email.

That's not to say everything will run smoothly as revenue cycles work to comply with all of the rule's requirements and moving parts.

"This is a massive bill to get a handle on," she says. "At the onset, I think there will definitely be some trial and error, especially with respect to the independent dispute resolution process."

She offers Florida, where there is a specified state law, as an example.

There, she says their "clients are in the process of developing workflows and frameworks to ensure claims are timely submitted through the correct dispute resolution procedure."

That "includes identifying out-of-network claims early (and what type of claims they are), assigning certain codes to the claims within their EMR, reviewing EOBs through an expedited process to ensure the quick turn-around times under the federal dispute resolution process are met, batching the right claims together, and getting them to the right internal department or outside vendor once they have been underpaid," she says.

In addition, Greenfield says another issue that will likely come up for revenue cycles as they attempt to comply with the rule is parameters surrounding the notice and consent process, such as when the notice and consent process can be used.

"For example, understanding how the agency defines post-stabilization services and when balance billing prohibitions can be waived," she says.

HealthLeaders checked in with revenue cycle leaders across the country via email and phone to get a temperature check on the first few weeks of this landmark rule. Here's what five of them had to say:  

Stephanie Wells, system vice president of revenue cycle/HIM, and Katherine Cardwell, vice president of revenue cycle, for Ochsner Health, Louisiana:

"Ochsner Health knows the pandemic and recent hurricanes [in Louisiana] have brought new difficulties to our patients and communities. While recent changes in federal law aim to protect against 'surprise' or 'balance' medical bills, the law covers practices Ochsner Health already commits to out of care for our patients’ healthcare and financial needs.

Transparency is important to Ochsner especially as our country continues to confront the COVID-19 pandemic. We are committed to helping our patients understand what they can expect to pay for care so they can make informed decisions.

Ochsner's Surprise Billing Disclosure document outlining Patient Rights and Protections Against Surprise Medical Bills is available on our website, is posted in registration areas, and is sent through email along with estimates. It is also offered by our financial call center when employees ask for pre-payment, is presented during e-pre-check of patients, and is offered by registration onsite.

Ochsner has also ensured that self-pay patients who scheduled at least three days in advance will receive an estimate for their care through their patient portal and via email. If electronic methods are not available, Ochsner prints and mails the estimates. Additionally, our scheduling team has scripting to notifying self-pay patients of their right to receive a good faith estimate. At the time of scheduling, we email patients information about patient rights and protections and explain how to obtain an estimate.

Estimates can be received through our self-service, cost estimator tool, which is available online, 24 hours a day, seven days a week at Our dedicated central pricing office is also available to provide patients with in-person assistance for tailored, personalized estimates based on individual circumstances, and our financial services team proactively calls patients and sends a message through the patient portal to inform patients of out-of-pocket costs.

Ochsner believes this regulation to be administratively burdensome and does anticipate there will be tweaks to how the law is implemented to address certain administrative processes for health systems. We will comply as new regulations implementing the No Surprises Act are clarified and come into effect."

Karen Kennedy, director, revenue cycle, Cleveland Clinic, Ohio and Florida:

"Our planning and preparation for implementation of the ​No Surprises Act (NSA) was led by a cross-functional team including high-functioning caregivers from IT, legal, patient access, billing, self-pay follow-up, and education.

Members of this team met weekly to create an overall strategy and manageable ongoing process that met all of the additional requirements of the NSA by January 1.

Although this implementation was complex and resource intensive, Cleveland Clinic completed its implementation by January 1 and fully supports the legislation to protect patients from surprise billing."

Candice Powers, chief revenue cycle officer, Mon Health System in West Virginia:

"The No Surprises Act has cemented the importance of pre-access services in our facilities. Mon Health will continue to evolve to meet the patient in their healthcare journey with accurate individualized estimates of the services they need.

As an industry, the tools necessary to be compliant with these requirements will also need to evolve. To be fully compliant, healthcare providers, payers, and technology service offerings will need to align quickly. Change is the only thing consistent in the healthcare space."

Sarah Ginnetti, associate vice president of revenue cycle at UConn Health, Connecticut:

"As a result of preparing for that regulation to go into effect on January 1, we did stand up another cross-functional team in the organization. We found a way to develop some workflows within Epic [and] identify the right team members to assign to some of this work in order to manage and respond to the No Surprises Act.

I think we actually have a pretty good process in place. It is very manual and that's the one thing I don't like about it. But we right now don't have the infrastructure set up around it to make it a more automated process. However, that is part of our roadmap going forward that's tied to the patient experience. [That will include] building out our estimate platform.

For all intents and purposes, we are, I would say, 90-plus percent compliant, and were as of January 1."

Alexandra Wilson Pecci is an editor for HealthLeaders.


Revenue cycles are making a good-faith effort to comply with the rule.

The rule is administratively burdensome and still comes with a lot of unanswered questions.

Revenue cycle leaders appreciate the spirit of the No Surprises Act and agree that patients shouldn't be hit with surprise hospital bills.

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