Understanding the Impact of the No Surprises Act on Office-Based Practices

Introduction
The healthcare billing landscape has undergone significant changes with the implementation of the No Surprises Act (NSA). This federal legislation was introduced to protect patients from unexpected medical bills, particularly those that arise when patients unknowingly receive care from out-of-network providers. While the law is often associated with hospitals and emergency care, its impact extends just as strongly to office-based and ambulatory practices.
For practice managers, compliance officers, and billing teams, the NSA introduces new responsibilities around billing transparency, documentation, and patient communication. Office-based practices must now ensure that estimates are accurate, billing workflows are compliant, and patients are fully informed about their financial responsibilities before care is delivered. Understanding these requirements is crucial for avoiding penalties, minimizing disputes, and maintaining patient trust.

What Is the No Surprises Act?

The No Surprises Act is a federal healthcare law designed to eliminate surprise medical billing. Surprise bills commonly occur when patients receive care from out-of-network providers without their knowledge, often resulting in significant and unexpected financial burdens.
Under the NSA, patients are protected from being balance billed for certain emergency services and specific non-emergency services provided by out-of-network clinicians. The law also places a strong emphasis on cost transparency by requiring providers to disclose estimated charges in advance. For office-based practices, this means adopting clearer billing practices and ensuring patients are not caught off guard by unexpected costs.
What Is the No Surprises Act

Who Must Comply with the No Surprises Act?

A common misconception is that the No Surprises Act applies only to large hospitals or emergency departments. In reality, many office-based and ambulatory practices are subject to the law’s requirements. Any practice that provides services to uninsured or self-pay patients, or participates in situations where out-of-network billing may occur, must comply with NSA regulations.
Primary care clinics, specialty practices, ambulatory surgical centers, behavioral health providers, and diagnostic facilities all fall within the scope of the Act. As a result, compliance is not limited to a specific type of practice but applies broadly across outpatient healthcare settings.
Who Must Comply with the No Surprises Act

Key Requirements of the No Surprises Act

The No Surprises Act introduces several core requirements that directly affect how office-based practices operate. These requirements focus on preventing balance billing, increasing transparency, and ensuring patients are informed about their rights.
Practices are prohibited from billing patients beyond allowed amounts for covered services, which limits the ability to collect unexpected charges. They are also required to provide Good Faith Estimates to eligible patients, outlining the expected cost of care before services are rendered. In addition, practices must share clear disclosures explaining patient protections under the law and participate in dispute resolution processes when billing disagreements arise. Accurate documentation and record retention are essential, as compliance may be reviewed during audits or investigations.

Good Faith Estimates Explained

One of the most impactful provisions of the No Surprises Act for office-based practices is the requirement to provide Good Faith Estimates, commonly referred to as GFEs. These estimates must be given to uninsured or self-pay patients and should include a clear breakdown of the expected costs associated with scheduled services.
The timing of the estimate depends on how far in advance the service is scheduled. If a service is scheduled at least ten business days ahead, the estimate must be provided within three business days. For services scheduled three to nine business days in advance, the estimate must be delivered within one business day. For same-day services, the estimate must be provided upon the patient’s request.
If the final bill exceeds the Good Faith Estimate by four hundred dollars or more, patients have the right to initiate a formal dispute. This makes accuracy critical and places additional responsibility on billing teams to ensure estimates reflect realistic costs.
Good Faith Estimates Explained

Billing Implications for Office-Based Practices

The No Surprises Act has significantly reshaped billing workflows for office-based practices. Billing teams must now operate with greater precision, as errors can lead to disputes, delayed payments, or regulatory scrutiny.

Accurate coding and charge capture have become more important than ever, as even small discrepancies can result in non-compliance. Billing staff must also maintain thorough documentation to support estimates and final charges. Additionally, traditional balance billing practices are no longer permissible in many situations, which can affect revenue if workflows are not properly adjusted. Practices that rely heavily on manual processes or outdated billing systems may find it more challenging to meet these new standards.

Patient Communication Under the NSA

Clear and proactive patient communication is a cornerstone of the No Surprises Act. Office-based practices are now expected to explain billing protections, estimated costs, and patient rights in a way that is easy to understand.
Effective communication involves providing written estimates and disclosures, ensuring front-desk and billing staff are trained to answer patient questions, and setting expectations before services are delivered. When patients understand their financial responsibilities upfront, practices are more likely to avoid confusion, disputes, and dissatisfaction after care has been provided.

Common Compliance Challenges

Despite understanding the requirements, many office-based practices encounter challenges when implementing NSA compliance. Inaccurate estimates often result from poor coordination between clinical and billing teams. Missed deadlines can occur when workflows are not automated or clearly defined. Inconsistent patient disclosures may stem from staff training gaps, while billing disputes frequently arise due to coding or documentation errors.
These challenges demonstrate that compliance is not solely a billing issue but an operational one that requires coordination across departments.

How Office-Based Practices Can Prepare

Preparation for NSA compliance requires a proactive and structured approach. Practices should begin by reviewing their current billing workflows to identify gaps or inefficiencies. Standardizing processes for generating Good Faith Estimates can reduce errors and improve consistency. Ongoing staff training is also essential to ensure everyone understands their role in compliance.
Strengthening documentation practices and maintaining audit readiness can further reduce risk. Many practices also benefit from partnering with experienced revenue cycle management professionals who understand the regulatory landscape and can help implement compliant workflows.

How MaxRemind Supports No Surprises Act Compliance

Navigating the complexities of the No Surprises Act can be challenging without expert support. MaxRemind helps office-based practices align their billing operations with NSA requirements by ensuring accuracy, transparency, and compliance throughout the revenue cycle.

Through structured billing workflows, support for Good Faith Estimates, and reduced risk of billing disputes, MaxRemind enables practices to stay compliant while protecting revenue. By keeping billing processes aligned with CMS guidelines, MaxRemind helps practices remain audit-ready and focused on delivering quality patient care.
How MaxRemind Supports No Surprises Act Compliance

Final Thoughts

The No Surprises Act represents a long-term shift toward greater transparency and patient protection in healthcare billing. For office-based practices, compliance is now a fundamental operational responsibility rather than a regulatory afterthought.
Practices that invest in accurate billing workflows, strong patient communication, and expert revenue cycle support will be best positioned to succeed under NSA requirements. With the right approach and the right partner, compliance becomes manageable and sustainable. MaxRemind supports practices every step of the way, helping them navigate regulatory change with confidence while maintaining financial stability.

Stay Compliant. Protect Revenue. Build Patient Trust.

Ensure your practice meets No Surprises Act requirements with accurate estimates, compliant billing workflows, and expert RCM support from MaxRemind.
FAQs
Does the No Surprises Act apply to office-based medical practices in the United States?

Yes, the No Surprises Act applies to many office-based medical practices across the United States. Any practice that treats uninsured or self-pay patients or may be involved in out-of-network billing scenarios is required to comply. This includes primary care clinics, specialty practices, behavioral health providers, and ambulatory surgical centers operating in both urban and rural areas.

What are the Good Faith Estimate requirements for outpatient practices under the No Surprises Act?

Under the No Surprises Act, outpatient and office-based practices in the U.S. must provide Good Faith Estimates to uninsured or self-pay patients before services are delivered. These estimates should clearly outline expected charges and must be provided within specific timeframes depending on when the service is scheduled. Accurate estimates are essential, as patients can dispute bills that exceed the estimate by $400 or more.

How does the No Surprises Act affect medical billing workflows for U.S. practices?

The No Surprises Act significantly impacts medical billing workflows by requiring greater accuracy, transparency, and documentation. U.S. practices must adjust their revenue cycle processes to ensure compliant coding, timely estimates, and clear patient disclosures. Many practices are turning to professional billing and compliance support to reduce administrative burden and minimize the risk of disputes or penalties.

What penalties can office-based practices face for No Surprises Act noncompliance?

Office-based practices in the United States that fail to comply with the No Surprises Act may face financial penalties, patient disputes, and regulatory scrutiny. Noncompliance can result from missing Good Faith Estimate deadlines, inaccurate billing, or improper patient communication. Staying compliant requires ongoing monitoring of billing practices and adherence to CMS guidelines.

How can U.S. office-based practices stay compliant with the No Surprises Act?

U.S. office-based practices can stay compliant with the No Surprises Act by standardizing billing workflows, improving coordination between clinical and billing teams, and ensuring staff are trained on NSA requirements. Partnering with experienced revenue cycle management providers like MaxRemind can also help practices maintain compliance, reduce billing errors, and navigate ongoing regulatory changes with confidence.