No Surprises Act Compliance Guide

What Is the No Surprises Act?

The No Surprises Act (NSA), effective January 1, 2022, is federal legislation designed to protect patients from unexpected medical bills resulting from out-of-network care in emergency settings, at in-network facilities by out-of-network providers, and from air ambulance services. The law limits patient cost-sharing to in-network rates in these scenarios and establishes an independent dispute resolution (IDR) process for payment disputes between providers and insurers.

Key No Surprises Act Requirements

The No Surprises Act establishes several interconnected patient protections that affect how healthcare providers bill, communicate with patients, and resolve payment disputes. Understanding each requirement is essential for compliance — violations can trigger significant penalties and expose organizations to patient lawsuits. Healthcare providers and their collection partners must work together to ensure every account meets NSA standards before any collection activity begins.

• Balance billing prohibition — providers cannot bill patients beyond in-network cost-sharing amounts for emergency services, out-of-network services at in-network facilities, and air ambulance services
• Good Faith Estimates (GFEs) — providers must give uninsured or self-pay patients written estimates of expected charges before scheduled services
• Patient-provider dispute resolution — patients can dispute bills that exceed GFEs by $400 or more through a federal process
• Independent Dispute Resolution (IDR) — out-of-network providers and insurers resolve payment disputes through certified IDR entities
• Advanced Explanation of Benefits (AEOB) — insured patients must receive cost estimates before scheduled services (phased implementation)
• Provider directory requirements — health plans must maintain accurate provider directories and verify network status

Impact on Healthcare Collections

The No Surprises Act fundamentally changes how certain patient balances can be collected:

• Balance limitations — collections on emergency and specific out-of-network services are limited to in-network cost-sharing amounts
• GFE compliance — self-pay patients who didn't receive a required GFE may have grounds to dispute their bill
• Documentation requirements — collection agencies must verify that billed amounts comply with NSA before pursuing collections
• Dispute process awareness — collection activity may need to pause when patients invoke the NSA dispute resolution process
• Consent documentation — if a patient provided written consent to waive NSA protections, this documentation must be maintained

How MSB Ensures No Surprises Act Compliance

Midwest Service Bureau has built No Surprises Act compliance into every aspect of our healthcare collection processes. With over 55 years of healthcare collections experience from our headquarters in Wichita, Kansas, MSB has navigated every major regulatory shift in healthcare billing — from HIPAA implementation to CFPB Regulation F to the No Surprises Act. Our compliance infrastructure is designed to protect both patients and providers, ensuring that every account we work meets current federal and state requirements before any collection activity begins. We operate on a no-recovery, no-fee basis, so your organization bears no financial risk while gaining a compliance-focused collections partner.

• Account-level NSA screening — every placed account is reviewed for NSA applicability before collection activity begins
• Balance verification — we confirm that billed amounts comply with NSA limitations before contacting patients
• GFE awareness — our team is trained to handle patient inquiries about Good Faith Estimates and direct patients to appropriate dispute channels
• Dispute process compliance — we immediately pause collections when patients invoke NSA dispute resolution rights
• Ongoing training — our compliance team monitors CMS and HHS regulatory updates and adjusts our processes accordingly
• Client guidance — we help healthcare providers understand how NSA affects their accounts before placement