No Surprises Act Assessment to Mitigate Compliance and Revenue Risks

Bruce Adler

Bruce Adler

Vice President, Revenue Cycle Practice Director

 Health and Human Services (HHS) has proposed that it will conduct on average 200 random or targeted investigations per month into potential violations of No Surprises Act requirements by providers, starting in 2022” – (KFF No Surprises Act Implementation: What to Expect in 2022, Dec. 10, 2021)

In the case of providers, the federal government is authorized to impose civil monetary penalties of up to $10,000” – ( No Surprises Ace: A Federal-State Partnership to Protect Consumers from Surprise Medical fills, Oct. 20, 2022)

medSR can help your organization proactively mitigate the compliance risks of the No Surprises Act (NSA) and ensure you have the procedures in place to provide accurate and defensible patient estimates. Our comprehensive approach to assessing risks starts with an exploration of revenue cycle operations and proceeds through account resolution.

Our approach will provide a risk assessment of both Revenue Cycle procedures and compliance with content and notification requirements of the NSA. The assessment includes the following components:

Patient Access

  • Assess scheduling, verification, authorization, and point of service collections to support NSA requirements
  • Validate all required consents and disclosures were posted, provided, and retained
  • Confirm adherence to Good Faith Estimate (GFE) delivery timelines

Good Faith Estimate (GFE) Content

  • Validate the GFE contains all pertinent patient and provider demographics, service level costs, and disclosers
  • Confirm that all reasonably expected services and/or items are itemized
  • Discover readiness for co-provider/co-facility cost estimates
  • Retrieve issued estimates to support audit requirements

Balance Billing (Out-of-Network)

  • Confirm adherence to written notice and consent delivery timelines
  • Validate that all required content is present within notices and consents
  • Verify compliance with state balance billing regulations

Account Resolution

  • Assess A/R strategies for disputed accounts (Independent Dispute Resolution or Patient Provider Dispute Resolution)
  • Validate the accuracy of the GFE to what was documented, charged, and adjusted
  • Validate the appropriateness of cost-sharing adjustments
  • Confirm that payer compliance with NSA requirements was followed

The medSR Revenue Cycle Management team is a dynamic group of seasoned healthcare professionals who specialize in revenue cycle excellence. We leverage extensive industry knowledge to measurably improve revenue cycle performance.


Author: Bruce Adler, Vice President, Revenue Cycle Practice Director


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