How to Handle Surprise Medical Bills Post-No Surprises Act

The No Surprises Act, effective from January 1, 2022, has been a game-changer in protecting patients from unexpected, out-of-network medical bills. However, even with this legislation in place, chiropractic and physical therapy practices, along with their billers, must navigate the nuances of this law to ensure compliance and protect both the practice and its patients from the lingering issues of surprise billing. Here’s how to manage these scenarios effectively in 2025.

Understanding the No Surprises Act:

• Scope: The Act protects individuals from surprise bills for emergency services (even if out-of-network), non-emergency services from out-of-network providers at in-network facilities, and air ambulance services. For chiropractic and physical therapy, this often relates to situations where an ancillary provider, like an anesthesiologist during a procedure, might be out-of-network.
• Key Protections: Patients are only liable for in-network cost-sharing amounts, and providers cannot balance bill for the difference between their charge and what insurance covers.

Steps for Chiropractic and Physical Therapy Practices:

1. Education and Training:
   • Staff Awareness: Ensure all staff, especially those involved in billing, are well-educated about the No Surprises Act. This includes understanding when a bill could be considered a surprise and the steps to take to prevent it.
   • Patient Education: Inform patients about their rights under the Act. Provide clear, accessible information about network status, potential costs, and how to handle billing disputes.
2. Network Management:
   • Verify Network Status: Regularly check and update provider network status with insurance companies. This is crucial in chiropractic and PT settings where multiple practitioners might be involved in patient care.
   • Use In-Network Providers: When possible, coordinate care with in-network providers to avoid surprise bills. This might mean ensuring all staff in a multi-disciplinary practice are contracted with the same networks.
3. Good Faith Estimates:
   • Uninsured or Self-Pay: For patients without insurance or choosing not to use their insurance, provide a good faith estimate of the cost of care. This is now a requirement under the Act, helping to prevent surprise bills by setting expectations upfront.
4. Billing Practices:
   • Compliance with Cost-Sharing: Ensure that bills reflect only the in-network cost-sharing amounts for services covered by the Act. If an out-of-network provider was involved, their charges should be managed through the insurance plan, not passed directly to the patient.
   • Notice and Consent: In scenarios where out-of-network services are necessary and known in advance (like a specific chiropractor or physical therapist not in the patient’s network), obtain written consent from the patient after providing them with a notice about their rights.
5. Handling Discrepancies:
   • Dispute Resolution: If a patient receives a surprise bill, guide them on how to dispute it. This might involve contacting the insurer, the provider, or using the federal independent dispute resolution process if the bill exceeds the good faith estimate by more than $400.
   • Documentation: Keep thorough records of all communications, consent forms, and billing documents. This documentation can be crucial in resolving disputes or during audits.
6. Continuous Monitoring:
   • Stay Updated: The Act’s implementation might evolve with further clarifications, amendments, or legal interpretations. Stay informed through CMS updates, professional associations, and legal consultations to adapt billing practices accordingly.

The No Surprises Act significantly aids in reducing the incidence of unexpected medical bills, particularly in the nuanced fields of chiropractic and physical therapy where multiple providers might be involved. By adhering to these practices, chiropractic and PT billers can not only ensure compliance but also enhance patient trust and satisfaction. Proactive education, meticulous billing, and clear communication are key to navigating this new landscape of medical billing post-No Surprises Act.

Sources:

• CMS.gov (www.cms.gov) for detailed guidelines on the No Surprises Act.
• Consumer Financial Protection Bureau (www.consumerfinance.gov) for consumer advice on handling surprise bills.