By now, the No Surprises Act (NSA) has entered into the healthcare industry’s lexicon. Like many regulations, this law, which went into effect in January 2022, is designed to protect patients from undue financial strain. Inevitably, provider organizations (such as the American Medical Association (AMA) and the American Hospital Association (AHA)), have raised concerns about certain aspects of the law — specifically, implementation. As AMA Senior News Writer Andis Robeznieks put it, implementation is “very much a work in progress.”
In practice, of course, regulations cause implementation pains, and subsequent controversy. Everyone in the ARM industry knows those pains quite well. But in theory, almost all members of the healthcare ecosystem, from patient to provider, from revenue cycle leaders to coders, can get behind the No Surprises Act. After all, it was created to help patients do exactly what it sounds like: Avoid surprise medical bills from out-of-network providers.
A “surprise” bill is typically a balance bill: a bill that represents the difference between the amount the insurance plan will pay and the full amount of the service charged. These surprise bills usually occur in two scenarios: when a patient isn’t expecting to require services, such as in an emergency, or when they aren’t expecting a provider to be out-of-network (such as when they have an appointment at an in-network facility, for instance).
In those scenarios, estimating the totality of cost of care at the time said care occurs is next to impossible. Care delivery must occur regardless of insurance status, so correct balance bill estimation can take several days to catch up.
Because the No Surprises Act uses notification and consent to limit surprise, adhering to the nuances of such a regulation complicates operations for providers and their respective revenue cycle management teams.
Healthcare revenue cycle management is a detailed, evolving discipline to begin with, and the introduction of the No Surprise Act doesn’t seem to have pushed RCM toward simplification.
Indeed, as we write, healthcare revenue leaders the nation over are still searching for ways to architect new workflows that support the many new processes the NSA facilitates (such as dispute resolution) though they dialed in compliance before the Act took effect.
And while RCM leaders are no strangers to reworking a workflow, the updates aren’t easy — or free of cost. Implementation will continue to require new-hire investments, technology investments, and more. Even so, the best revenue leaders know that what you put in is what you get out; if the object is to better serve patients while remaining compliant and keep operating costs down, then moving forward empathy and intelligence (read: information) is the only way to move forward.
In this way, the Act isn’t only designed to protect patients. Its many implementation intricacies can fuel benefits in the revenue centers of organizations, too.
Greater accuracy in coding and charge capture, as well as the correct groupings of claims submissions, is a moving target. With the No Surprises Act in play, healthcare organizations have had to re-examine their front office processes and focus on developing stronger QA and analytics, which should support a reduction in disputes.
Because the No Surprises Act was conceived to protect patients, one of its central tenets is transparency, and one of its required motions is public notice of balance billing rights. In addition to the consumer’s overarching sense that billing is becoming more transparent, billers will have more opportunities to establish trust at the outset of a payments process — through consistency and commitment.
It’s not just QA that benefits from a re-examination. Retooling workflows to support early identification of issues can support a shortened billing cycle and a reduction in reliance on collections agencies or in-house collections administrators.
In the leadup to the No Surprises Act, revenue leaders have had to directly address workflow issues that don’t support both auditing and adherence to compliance mandates — regulations beyond the NSA. The implementation of a new law has given rev cycle managers the impetus to review their ability to respond to future regulations.
Those touchpoints we mentioned can go a long way toward establishing trust. And that type of transparency and sustained contact offers opportunities to engage that don’t take place in the collections phase of a payer/payee relationship. During those opportunities, such as patient registration and information dispersal, the positive interactions can bolster an improved, start-to-finish patient experience — and lessen resistance to payment long-term.
While implementation is ongoing, and controversy with it, the fact is, the NSA is in play. Best-in-class revenue leaders have been working for many months to support implementation while discovering ways the NSA can benefit RCM. It remains to be seen if all of the potential benefits we listed here will pan out in the coming months and years, but we’ll be keeping tabs on the numbers — administration costs, collections instances, and more — to find out.
Want to learn more about how collections success could impact healthcare RCM — and how conversational intelligence can benefit both? Talk to our industry experts today.
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