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AAMC Submits Comments on No Surprises Act Enforcement

October 22, 2021

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CONTACTS
Gayle Lee, Director, Physician Payment & Quality
Mary Mullaney, Director, Hospital Payment Policies

In response to a proposed rule on surprise billing, the AAMC sent a comment letter on Oct. 14 to the Departments of Health and Human Services, the Treasury, and Labor, and the Office of Personnel Management addressing enforcement of consumer protections against surprise billing, as well as proposals regarding telehealth and agent and broker compensation disclosures.

The letter urged the departments to delay enforcement of additional requirements under the No Surprises Act, part of the Consolidated Appropriations Act, 2021 (P.L. 116-260), until after the public health emergency ends to allow providers and hospitals to focus scarce resources on caring for patients. In the letter, the AAMC asked the Centers for Medicare & Medicaid Services (CMS) to make clear to providers and facilities which entity — CMS or the state — has enforcement authority over the No Surprises Act.

The letter also added, if a complaint is filed, that CMS allow a minimum of 30 business days for a provider or facility to respond to the CMS notice of the complaint and to allow for providers to seek an extension if necessary.

The letter also emphasized the importance of giving consumers all agent and broker compensation information for plans those agents and brokers market and sell, so consumers can evaluate whether they are being steered toward plans with high commissions and bonuses.

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