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AHIP Response To The Interim Final Rule Concerning Requirements Related To Surprise Billing; Part I

posted by AHIP

on September 7, 2021

No American should worry about receiving a surprise medical bill and the financial harm that can result. That is why AHIP remains eager to engage with the Administration as well as other health care stakeholders– including employers, providers, facilities, state governments, and consumers – to ensure the No Surprises Act is implemented in an efficient and effective manner.

On September 7, 2021, AHIP responded to the Interim Final Rule with Comment issued by the U.S. Departments of Health and Human Services, Treasury, Labor and the Office of Personnel Management, “Requirements Related to Surprise Billing; Part I” (“the IFC”), published July 13, 2021 in the Federal Register (86 FR 36872).

AHIP strongly supported legislative efforts to ban the practice of surprise medical billing. This egregious business model went on for far too long and eroded Americans’ confidence in our health care system while harming the financial security of millions of families each year.

These interim final rules are a crucial step towards ensuring surprise medical bills are part of our history, not our future. The IFC is a thoughtful and reasonable approach to address the care scenarios where surprise bills should be prohibited, the determination of a consumer’s cost sharing obligation, the methodology for the Qualifying Payment Amount, and the process for lodging complaints with respect to compliance with the No Surprises Act. The regulations as detailed in the IFC establish comprehensive protections for consumers in a wide array of care settings while going to great lengths to ensure consumer cost-sharing, often determined through the QPA, can be equitably determined. We offer comments on aspects of the IFC, including a series of technical comments and recommendations on how to ensure that health plans and issuers are best able to implement the No Surprises Act and that consumers are fully protected on January 1, 2022.

American consumers and patients are counting on us to get this right. We look forward to engaging with the Departments throughout the coming years to do just that.