E/M Coding Alert - 2021 Issue 10
Compliance: Get ‘Surprise Billing’ Disclosures in Place Now
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Article Overview
This article summarizes a recent federal interim final rule implementing surprise billing protections under the No Surprises Act. It explains the general scope of the rule, the types of organizations and services affected, the role of patient notice and consent, complaint handling, and the need to prepare website disclosures and model notices. The piece is aimed at surgery practices, providers, facilities, and compliance staff trying to understand upcoming obligations and prepare for implementation.
Why This Topic Matters
The article helps healthcare organizations understand new federal transparency and billing compliance requirements that affect patient communications and practice operations. It is relevant for teams responsible for payer contracting, disclosure notices, and policy updates tied to surprise billing restrictions.
Article Sections
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Know the Basics
Introduces the federal surprise billing framework and summarizes the main categories of services and settings addressed by the rule. It also notes the broad range of entities affected by the new requirements.
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Not All Balance Billing is Bad
Discusses the situations in which balance billing remains relevant under the rule and the general emphasis on patient transparency. It also mentions the availability of a model disclosure notice for compliance purposes.
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Patients Can Lodge Complaints
Describes the complaint process discussed in the rule and notes that additional timing and procedural details were still pending at the time of publication.
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Do These 4 Things Now
Outlines preparatory compliance steps for providers and practices, including reviewing payer relationships, updating patient communications, and preparing required notice materials.
What You Will Learn
- The general scope of the No Surprises Act interim final rule
- Which types of providers, facilities, and services are affected
- How patient notice, consent, and disclosure requirements are framed
- What compliance preparations practices were advised to make
- How complaints and future rulemaking fit into the implementation timeline
Who Should Read This
- Healthcare providers
- Surgery practices
- Compliance staff
- Practice managers
- Revenue cycle teams
- Payer contracting teams
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