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The No Surprises Act

The No Surprises Act (NSA) is a part of the Affordable Care Act. In a nutshell, the NSA ensures that patients are sent surprisingly high medical bills.

Estimate Types and The Need for Consolidation

Due to the strict time limitations associated with estimate types, the CY 2024 Proposed Rule acknowledged the need to consolidate patient estimate requirements across the Hospital Final Rule, Transparency in Coverage (TiC), and the NSA. 

They requested feedback from industry stakeholders on:

Consumer Focus

  • How aware are consumers thinking about healthcare pricing information available from hospitals? We solicit recommendations on raising consumer awareness. 
  • What elements of health pricing information do you think consumers find most valuable in advance of receiving care? How do consumers currently access this pricing information? What are consumers’ preferences for accessing this price information? 
  • Given the new requirements and authorities through TIC final rules and the NSA, respectively, is there still a benefit to requiring hospitals to display their standard charges in a “consumer-friendly” manner under the HPT regulations? 
  • How, if at all, and consistent with its underlying legal authority, could the HPT consumer-friendly requirements at § 180.60 be revised to align with other price transparency initiatives? 
  • Within the contours of the statutory authority conferred by section 2718(e) of the PHS Act, should the information in the hospital consumer-friendly display (including the information displayed in online price estimator tools) be revised to enhance alignment with price information provided under the TIC final rules and NSA regulations? If so, which data should be revised and how? 

Tool Effectiveness

  • How effective are hospital price estimator tools in providing consumers with actionable and personalized information? What is the minimum amount of personalized information that a consumer must provide for a price estimator tool to produce a personalized out-of-pocket estimate? 
  • How are third parties using MRF data to develop consumer-friendly pricing tools? What additional information is added by third parties to make standard charges consumer-friendly? 
  • Should we consider additional consumer-friendly requirements for future rulemaking, and to the extent our authorities permit? For example, what types of pricing information might give consumers the ability to compare the cost of healthcare services across healthcare providers? Is there an industry-standard set of healthcare services or service packages that healthcare providers could use as a benchmark when establishing prices for consumers? 

Turquoise Health submitted our comment on the proposed rule, including the need for consolidation. You can read our full comment here.