The Medical Group Management Association, which represents more than 15,000 medical groups comprising more than 350,000 physicians, penned an Aug. 2 letter asking CMS to give physician groups at least six months' notice before the enforcement of any more surprise billing requirements.
Five things to know:
1. The No Surprises Act established patient protections against balance billing and created cost transparency tools to empower patients making decisions about their healthcare.
2. On Jan. 1, 2022, several provisions of the legislation took effect, including federal protections against balance billing, as well as directives regarding uninsured and self-pay good-faith estimate requirements, continuity of care protections and provider directory requirements.
3. However, the MGMA letter said the No Surprises Act caused administrative burdens for practices because "the interim final rules establishing these new requirements were published with minimal time prior to the implementation date" and "additional clarifying information came after the new mandates took effect."
4. CMS and HHS indicated they will publish more rules related to the advanced explanation of benefits requirements, continuity of care protections and provider directory requirements. To avoid confusion among physician practices, the MGMA has asked CMS and HHS to provide at least six months after the publication of any final rule to implement requirements under the No Surprises Act before the enforcement date.
5. In addition, on Jan. 1, 2023, the convening and co-provider requirements related to the uninsured and self-pay good-faith estimate requirements will take effect, but the "administrative requirements and technical standards" necessary to implement these requirements have not been established, according to the MGMA.
The MGMA urged CMS and HHS to delay the implementation of these requirements to allow physician practices — many of which are facing "staffing shortages, record-breaking inflation and significant reductions in Medicare payment" — more time to understand them and install effective protocols.