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Association Comments on Second Part of Surprise Billing Rules

In a letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals commented on the second interim final rule implementing the No Surprises Act.

The rule was released by the departments of Health and Human Services (HHS), the Treasury, and Labor and the Office of Personnel Management. Part I of the interim final rule established which services are protected from balance billing and payment methodology for out-of-network services. Part II of the rule outlines the independent dispute resolution (IDR) process for out-of-network services and protections for uninsured and self-pay patients, including good faith estimates.

Based on these provisions, the association urged HHS to:

  • revise good faith estimate requirements to account for the challenges of providing care to patients with complex social and financial needs;
  • create an IDR process that does not favor payers over providers serving a safety net role; and
  • review concerns from the association’s comments on Part I in regards to the qualifying payment amount calculations, the interaction between federal and state laws, and the Jan. 1, 2022, start date for this rule.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.

About the Author

Julie Kozminski is a senior policy analyst at America's Essential Hospitals.

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