The American College of Radiology® (ACR®) submitted input to U.S. Health and Human Services Secretary Xavier Becerra about implementation of the No Surprises Act (NSA) included in the Consolidated Appropriations Act of 2021. The ACR shares the goal of keeping patients out of the middle of billing disputes, while also addressing payer network adequacy issues that sometimes lead to “surprise medical billing.”
While the intent of the NSA is clear — to end surprise billing while preserving access to care — there are several policies in the Act that require further clarification through rulemaking. The ACR outlines main issues that should be addressed in rulemaking in its May 11 letter. Issues include defining the initial payment and qualifying payment amount, interaction of federal and state laws, and the independent dispute resolution process.
The ACR said fair payment mechanisms are necessary to ensure adequate reimbursement for out-of-network services in order to support a sustainable healthcare system and that the NSA represents a reasonable solution that promotes good-faith negotiations between payers and providers.
Questions about the No Surprises Act should be directed to Katie Keysor, ACR Senior Director of Economic Policy.