What Is the No Surprises Act?

The No Surprises Act is a landmark federal law that went into effect on January 1, 2022. It’s designed to protect patients from unexpected and often costly medical bills due to out-of-network health care. These additional costs or out-of-pocket expenses are commonly referred to as “surprise billing.”

Surprise bills typically occur when patients unknowingly or unexpectedly receive care from out-of-network providers, even though they sought treatment at in-network facilities. The most common scenarios involve emergency care or ancillary services during scheduled procedures—such as those provided by anesthesiologists, pathologists, or radiologists—that may not be in the patient’s insurance network.

The legislation applies to most private health insurance plans, including employer-sponsored coverage and plans purchased through the Affordable Care Act (ACA) marketplaces. It sets clear limits on how and when out-of-network providers can bill patients, shifting the burden of cost disputes away from patients and onto insurers and providers.
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How Are Insured Patients Protected Under the No Surprises Act?

Thanks to the No Surprises Act, patients are shielded from unexpected charges in several high-risk billing situations where they might otherwise receive a surprise medical bill. This applies to patients who have individual or group medical insurance. Patients who are using government-funded care such as Medicare and Medicaid are already protected from these expenses.

In each of these situations, patients are only responsible for standard in-network cost-sharing amounts, such as co-pays, deductibles, or coinsurance. Providers are prohibited from balance billing—that is, charging the patient the difference between what the provider charged and what the insurer paid.

1. Emergency Services

Patients who receive emergency care, whether at a hospital or a freestanding emergency department, cannot be charged more than the in-network rate. This is true even if the facility or provider is out-of-network. This protection also extends topost-stabilization care, which often follows an emergency visit and was previously a major source of surprise bills.

2. Non-Emergency Services at In-Network Facilities

If a patient receives non-emergency care at an in-network hospital or ambulatory surgical center, they cannot be billed at out-of-network rates for services provided by supporting clinicians unless the patient is properly notified and consents to out-of-network care. This includes anesthesiologists, assistant surgeons, and diagnostic labs.

3. Air Ambulance Services

Out-of-network air ambulance services can result in some of the highest surprise bills in healthcare. These services must now be billed at in-network cost-sharing rates. This provision does not yet apply to ground ambulance services, which are regulated at the state level and are currently under separate policy review.
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What Does the No Surprises Act Mean For Uninsured Patients?

In addition to protections for insured individuals, the law includes a vital provision for uninsured or self-pay patients. These patients now have the right to receive a Good Faith Estimate (GFE) of expected charges before receiving scheduled non-emergency care. The GFE must:

• Be provided in writing before the service date.
• Include expected costs from all providers and facilities involved. 
• Help patients compare costs and avoid unexpected financial burdens.

This provision promotes price transparency and empowers patients to plan for their care with greater confidence.

READ MORE: How Good Faith Estimates Vary By Specialty
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What Does the No Surprises Act Mean for Providers and Insurers?

The No Surprises Act not only protects patients, but it also significantly changes how healthcare providers and insurers handle out-of-network billing disputes. Patients who receive a bill for more than $400 over their GFE can dispute the charges within 120 days.

If there is a disagreement over reimbursement:

1. Negotiation is the first step between the provider and insurer.
2. If a resolution cannot be reached, either party can initiate an Independent Dispute Resolution (IDR) process.
3. The IDR process is managed by a neutral third-party arbitrator, who evaluates both parties’ offers and selects one—encouraging fair and reasonable billing practices.
   

Providers are also required to:

• Inform patients of their rights under the No Surprises Act.
• Obtain written consent if the patient agrees to receive care from an out-of-network provider knowingly (only applicable in non-emergency situations).
• Submit timely and accurate documentation to participate in the IDR process.

READ MORE: What Is Price Transparency In Healthcare?
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Why Does the No Surprises Act Matter?

The No Surprises Act represents a critical step forward in patient financial protection. By eliminating most surprise bills and enforcing up-front cost disclosure, the legislation supports the broader movement toward transparency, accountability, and fairness in healthcare pricing.

At careviso, we share this mission. Our healthcare transparency platform enables:

• ‍Real-time cost estimates based on insurance coverage and procedure codes.‍
• Streamlined prior authorization workflows, reducing delays in care.‍
• End-to-end transparency across financial and administrative processes.

These tools help providers operate more efficiently while ensuring patients have the information they need to make informed, confident healthcare decisions.

CASE STUDY: Navigating the No Surprises Act With seeQer
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What Is the Future of the No Surprises Act?

While the No Surprises Act provides substantial protections, implementation and compliance are still evolving. The law has faced ongoing legal challenges, operational delays, and the need for clarifying guidance—especially around the IDR process. As updates continue, providers, payers, and health tech organizations must stay agile and informed.

READ MORE: No Surprises Act 4 Years Later: What’s the Status of Healthcare Transparency?

At careviso, we remain committed to:

• Helping providers adapt to new transparency and billing requirements.
• Building solutions that reduce administrative complexity.
• Supporting patients with tools that make care more accessible, affordable, and understandable.

By embracing innovation and collaboration, we can move toward a healthcare system that prioritizes clarity, choice, and trust—while still providing the exceptional care that patients need.