Reminder: Certain Requirements in the No Surprises Act Apply to Electrophysiologists

January 1, 2024 – On January 1, 2022, many provisions of the No Surprises Act went into effect. This statute created provisions intended to protect patients from the costs of unexpected “surprise” bills for out-of-network services provided in certain facility settings.

While many of the provisions only apply to situations where patients are treated by out-of-network providers, it is important to remember that, in addition to these protections, the statute and regulations created more general obligations for providers. These include the following:

• Disclosing the protections to patients via several different methods.
• Providing notice to patients who are eligible to consent to waiving their balance billing protections for certain non-emergency services.
• Furnishing a good faith estimate (GFE) of expected charges to an uninsured or self-pay individual when a non-emergency service is scheduled or when the uninsured or self-pay individual requests it; and, though not yet in effect, to insured individual’s health plans so the plan can distribute an “Advanced Explanation of Benefits” (Advanced EOB).

It is important that electrophysiologists are aware of these requirements and understand when they apply even if you do not routinely bill out-of-network patients.