No Surprises Act—Provider Obligations in 2022

The key provisions of the No Surprises Act and its implementing regulations will be effective beginning January 1, 2022, creating significant compliance obligations for a wide range of health care providers.  Although the surprise billing provisions of the law focus on billing for out-of-network facility and professional emergency services and out-of-network professional services furnished at in-network facilities, it also imposes a “good faith estimate” requirement that imposes significant new price transparency obligations that apply more generally to health care facilities (including hospitals, CAHs, ASCs, FQHCs, and RHCs) and professionals.