What is the No Surprises Act—and Why it Matters for Billing and Collections

The No Suprises Act is a federal law that took effect on January 1,2022, designed to protect patients from unexpected medical bills caused by unknowingly receiving care from out-of-network providers. These unexpected charges, known as “surprise bills,” typically occur during emergency visits or when services like anesthesia, radiology or pathology are performed by out of network specialists—despite the patient seeking care at an in-network facility.
The law applies to most private health insurance plans, including employer-sponsored plans and those purchased on the Affordable Care Act (ACA) market. It limits how and when out-of-network providers can bill patients, shifting the financial burden off patients and onto payers and providers.
At FFR, we stay fully informed of these regulations, so our healthcare clients remain compliant—and their patients are treated fairly and compassionately throughout the recovery process.
At FFR, we stay fully informed of these regulations, so our healthcare clients remain compliant—and their patients are treated fairly and compassionately throughout the recovery process.
How Patients Are Protected
Under the No Suprises Act, patients with private insurance are protected from many forms of surprise billing. Government programs like Medicare and Medicaid are already protected by existing laws.
For some situations, patients only owe their in-network cost sharing amounts—like copays or deductibles. Providers are prohibited from balance billing which means they cannot charge patients for the difference between what the provider charges and what the insured patient pays.
Key Protections include:
- Emergency Services
Patients receiving emergency care at a hospital or freestanding ER can only be charge in-network rates—even if the provider or facility is not in-network. These protections also cover post-stabilization care (which used to be a major source of surprise billing.
- Non-Emergency Services at In-Network Facilities
If a patient receives scheduled care at an in-network hospital or center, they cannot be billed out-of-network rates by any supporting providers (ex: anesthesiologists or diagnostic labs) unless they are given clear notice and consent to receive out-of-network care.
- Air Ambulance Services
Out of network air ambulance services must now be billed at in-network cost (Note: Ground ambulance services are still regulated by state laws and not yet covered under the No Suprises Act.)
Uninsured or Self-Pay Patients
For patients who are uninsured or choosing to pay out of pocket, the law includes a new requirement called the Good Faith Estimate (GFE).
This ensures that patients receive a written estimate of costs prior to receiving non-emergency services. The GFE must include:
- Total expected charges from all involved providers/facilities
- An estimate before services are rendered
- A way for patients to compare prices and avoid financial surprises
Price transparency helps patients make informed choices—and it helps providers and collection agencies like FFR, work from a position of clarity and trust.
What does this mean for Providers and Insurance Companies?
The No Suprises Act introduces a new dispute resolution process for billing discrepancies between providers and insurance companies. If a patient receives a bill more than $400 above their Good Faith Estimate, they can dispute the charges within 120 days.
Providers are also responsible for:
- Notifying patients of their rights under the Act
- Getting written consent for out-of-network care (non-emergency cases)
At FFR, we collaborate with providers to ensure that all collection efforts are complaint with current regulations and patients’ rights.
Why It Matters for Billing and Recovery
The No Surprises Act is a turning point for the healthcare revenue cycle. By cutting down surprise bills and making costs clearer, it helps build more trust between patients, providers and insurers.
As a third-party collection agency with 30+ years of experience, FFR understands how essential that trust is. That is why we:
- Stay current on evolving billing regulations and compliance
- Tailor our collection strategies to support both patient understanding and client reimbursement.
- Collet with compassion and professionalism, every step of the way.
Looking Ahead: Updates and Compliance
The No Surprises Act is currently in effect, but its details are still evolving. Challenges remain and new guidance keeps coming. Providers, insurers and partners, like FFR need to stay flexible and informed as regulations develop.
At FFR. We’re committed to:
- Helping clients understand and adapt to changing billing practices
- Ensuring all collections are handled with full legal and ethical compliance
- Supporting patient communication with transparency and compassion
Let’s work together to build a healthcare system where billing makes sense, expectations are clear and patients are aways treated with respect.