By: Winona Thomas BS HCS

The federal No Surprises Act establishes new requirements for healthcare providers, facilities, and providers of air ambulance services to protect consumers from “surprise” medical bills.

What are the impacts to healthcare providers with this new act in place for 2022?

Previously, when the provider office received a payment as an out-of-network payment from the payer, the typical patient accounting office process was to balance bill the patient for the disallowed charges or the charges that would be considered as the contractual allowance. With the No Surprise Act, healthcare providers, facilities, and providers of air ambulance services will no longer be able to just bill the patient for a doctor’s office visit with an out-of-network provider. This process was known as balance billing the patient for the non-covered out-of-network charges. Healthcare providers are now faced with the challenge of implementing new processes for non-participating providers disallowed charges and how to pursue the non-covered charges with non-contracted payers.

What does the No Surprise Act state?

Beginning January 1, 2022, non-participating emergency facilities and non-participating providers cannot bill insured consumers who receive emergency services at a hospital or an independent free-standing emergency department for a payment amount greater than the patient’s in-network cost-sharing requirements.

In addition, non-participating providers operating at a participating health care facility and providing non-emergency services to the insured patient cannot bill the patients an amount greater than the in-network cost-sharing requirement, unless the provider has obtained signed written consent from the patient.

Furthermore, the No Surprise Act goes on to state, “providers are not permitted to request consents to balance bill patients for the following list of ancillary services:

  • Items and services related to emergency medicine, anesthesiology, pathology, radiology and neonatology
  • Items and services provided by assistant surgeons, hospitalist, and intensivists
  • Diagnostic services, including radiology and laboratory services
  • Items and services provided by a non-participating provider if there is no participating provider who can povide an item or service at that facility

For further information about the No Surprise Act 2022, the Center for Consumer Information & Insurance Oversight (CCIIO) at

Winona L. Thomas, BS HCS is an Account Specialist and Writer at MedCycle Solutions, which provides Revenue Cycle Management, Credentialing, Outsourced Coding, and Consulting Services to a number of healthcare providers in a variety of specialties. To find out more information about MedCycle Solutions services, please visit