What is the No Surprises Act?
The No Surprises Act protects patients from surprise out-of-network bills, requires good faith estimates for uninsured and self-pay patients, and sends payer and provider payment disputes to independent dispute resolution.
Out-of-network payment dispute
| Step | Deadline |
|---|---|
| Payer sends initial payment or denial | Within 30 days of the claim |
| Open negotiation, started by either side | Within 30 business days of that payment |
| Negotiation period | 30 business days |
| Start independent dispute resolution | Within 4 business days after negotiation ends |
- Miss a deadline and the right to dispute that payment is lost.
The No Surprises Act took effect on January 1, 2022. It changed what providers can bill patients and how out-of-network payment disputes are settled.
What it covers
- Surprise bills: emergency care, and non-emergency care from out-of-network providers at in-network facilities, can only be billed to the patient at in-network cost sharing.
- Good faith estimates: uninsured and self-pay patients get an estimate before scheduled care. If the bill is $400 or more above it, the patient can dispute it.
- Payer disputes: when a provider disagrees with a payer’s out-of-network payment, the two negotiate, then either can take it to independent dispute resolution (IDR), where an arbiter picks one side’s offer.
Why it matters for billing
Balances protected by the Act can’t move to patient responsibility beyond in-network cost sharing, and IDR has strict deadlines, so out-of-network short pays need to be tracked from the day they’re paid.
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