Interim Final Rule Aims to Protect Healthcare Consumers from Surprise Billing

Starting January 1st, 2022, healthcare consumers will find new protections in place against unexpected, out-of-pocket costs associated with surprise billing.

Requirements Related to Surprise Billing; Part I: The No Surprises Act, which was enacted as part of the Consolidated Appropriations Act 2021, contains interim final rules which protect patients and guarantors enrolled in health benefits from surprise medical bills when receiving emergency services, non-emergency services from non-participating providers at participating facilities, and air ambulance services from non-participating providers of air ambulance services.

The Department of Health and Human Services (HHS) is also issuing additional, interim final rules which apply to emergency departments of hospitals, independent freestanding emergency departments, health care providers and facilities, and providers of air ambulance services as they related to the protections against surprise billing.

The Journal of AHIMA published an article stating that, in addition to focusing on patient protections, the rules’ focus is also on defining key terms, including the “Qualifying Payment Amount” (QPA). The article states the QPA is defined as “…the median of contracted rates for the ‘same or similar items or services’ in a particular geographic area. For protected services, the patient’s proportional cost-sharing obligations must reflect what the patient would have paid for in-network care.”

Key patient protections, per the Journal of AHIMA, included in the interim final rule include:

• Banning surprise billing for emergency services. Emergency services, regardless of where they are provided, must be treated on an in-network basis without requirements for prior authorization.

• Banning out-of-network charges for ancillary care at an in-network facility.

• Banning high out-of-network cost-sharing for emergency and certain non-emergency services.

• Banning other out-of-network charges without advance notice.

Coding and billing responsibly is a priority for MCC’s RemitOneTM platform. By removing the administrative burden from the provider, clean and compliant claims are submitted and paid correctly the first time, ensuring the patient isn’t left with surprise billing charges.

If you’re a healthcare provider looking to submit clean, compliant claims that process correctly on the first submission, contact our team at info@mccremitone.com to find out how you can utilize RemitOneTM to improve clinical documentation, coding, and compliance, all while providing quality patient care.

To see more about MCC and RemitOne, visit our documentary segment that aired on CNBC here: https://www.mccremitone.net/r1video/MCC_03.mp4.

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