The No Surprises Act, enacted in 2022, is a landmark federal law designed to protect patients with both group health insurance and individual health plans from unexpected medical bills. This critical legislation aims to prevent patients from receiving surprise charges in multiple healthcare situations, including emergency medical services, non-emergency care from out-of-network providers at in-network facilities, and out-of-network air ambulance services.
The Act also establishes an Independent Dispute Resolution (IDR) process to help resolve payment disputes between healthcare providers and insurance companies, ensuring patients aren’t caught in the middle of billing conflicts.
Key Provisions of the No Surprises Act
The No Surprises Act protects individuals with private health insurance from some of the most common types of surprise medical billing. For uninsured or self-pay patients, it requires healthcare providers to give a Good Faith Estimate (GFE) of treatment costs before care begins.
If the final bill significantly exceeds the estimate, patients can formally dispute the charges. These provisions strengthen medical billing transparency and protect consumers from predatory pricing practices that have historically burdened patients.
What Does the No Surprises Act Cover?
The law is divided into two key sections that define provider obligations and patient rights:
Part I: Air Ambulance Services and Provider Enforcement
This section focuses on air ambulance billing restrictions and surprise charges from non-participating providers in participating facilities. It applies primarily to hospital and emergency care settings and does not include chiropractic services provided in-office.
Part II: Surprise Billing and Good Faith Estimates
This section establishes requirements for Good Faith Estimates, ensuring patients understand treatment costs before receiving care. Chiropractors and other healthcare providers must determine when such estimates are necessary and provide them within the required time frame.
The Importance of Good Faith Estimates (GFE)
At the core of the No Surprises Act is the Good Faith Estimate, which helps patients make informed decisions about their care and avoid unexpected bills.
According to the Western States Chiropractic Association (WSCA), a valid GFE must include:
- A detailed list of expected services and prices
- Applicable CPT and ICD-10 codes
- Patient and provider identifying information
- The scheduled appointment date
- Required legal disclaimers
Providers must deliver this information in writing or verbally within a specific time window before the scheduled appointment, allowing patients to compare costs and plan ahead.
How the No Surprises Act Interacts with State Laws
The No Surprises Act serves as a federal baseline for consumer protections, complementing state-level surprise billing laws. If a state already provides greater protections or has a stronger dispute resolution system, the state law takes precedence.
For example, if a state’s dispute process for self-pay consumers meets or exceeds federal standards, any billing disputes will be handled at the state level rather than through the federal IDR system.
This dual structure ensures that patients receive the highest level of protection possible, whether under federal or state jurisdiction.
Implementation and Compliance Timeline
The No Surprises Act took effect on January 1, 2022, fundamentally changing how healthcare providers and insurers manage billing for out-of-network and emergency services. Chiropractors and other providers must now understand and comply with Good Faith Estimate requirements to avoid federal penalties and ensure patient confidence in transparent pricing.
Why It Matters for Chiropractic Providers
Although chiropractors are not typically involved in emergency or air-ambulance billing, the Good Faith Estimate rule directly impacts chiropractic offices, especially when treating self-pay or uninsured patients.
By implementing clear cost estimates and transparent communication, chiropractors can improve patient trust, reduce billing disputes, and maintain full compliance with federal healthcare law.