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AAMC Submits Comments on Surprise Billing Interim Final Rule

September 3, 2021

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CONTACTS
Mary Mullaney, Director, Hospital Payment Policies

On Aug. 31, the AAMC submitted comments in response to the Requirements Related to Surprise Billing, Part 1 interim final rule (IFC). The IFC implements certain provisions of the No Surprises Act, which was part of the Consolidated Appropriations Act, 2021 (P.L. 116-260) [refer to Washington Highlights, Dec. 23, 2020, July 9, 2021].

The comments outline the AAMC’s support of protecting patients from surprise medical bills and promoting price transparency. However, it calls on the Department of Health and Human Services (HHS) to consider the uniqueness of teaching hospitals and the patients they serve when implementing the No Surprises Act. Given the complexities of the legislation, the letter calls on the HHS to delay its implementation by one year to allow providers and payers to make necessary system changes to ensure a seamless transition.

Highlights of the letter include recommendations to:

  • Account for the highly specialized care provided by teaching hospitals and their associated providers in the qualified payment amount and median contracted rates.
  • Include out-of-network rates and single case arrangements in the calculation of the median contracted rates.
  • Require transparency of the methodology and data used to calculate the qualifying payment amount and median contracted rates. 
  • Monitor patients’ access to tertiary and quaternary care and access to out-of-network specialists when receiving care at in-network facilities.
  • Not allow self-funded plans to opt in or opt out of state surprise billing laws.

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