Recent federal layoffs have added a new layer of uncertainty for providers impacted by the No Surprises Act.
The federal office responsible for implementing this critical legislation faces staffing cuts, so revenue cycle leaders must stay proactive to mitigate the impact of surprise billing on their organizations. While the future of surprise billing legislation may be in limbo, providers can take actionable steps to strengthen their revenue cycle operations, including leveraging medical billing services and partnering with the best medical billing company in the USA to support compliance and financial stability.
Recent Federal Layoffs Jeopardize the No Surprises Act
The No Surprises Act, signed into law in 2020, was designed to protect USA medical billing patients from unexpected medical bills, especially out-of-network care. The federal Center for Consumer Information and Insurance Oversight (CCIIO) has been responsible for implementing this legislation, including establishing an independent dispute resolution (IDR) process to mediate billing disagreements between providers and payers. But recent layoffs have significantly weakened the CCIIO, with 15% of its workforce – 82 employees – being let go. These cuts have left the agency struggling to manage the overwhelming volume of disputes, which exceeded 650,000 cases in 2023 alone [1].
The CCIIO’s ability to streamline the IDR process and enforce the No Surprises Act has been compromised, creating uncertainty for providers and their revenue cycle departments. As Jeff Grant, former deputy director of the CCIIO, noted, the layoffs have thrown the agency into chaos, delaying critical rule-making and leaving the future of surprise billing legislation in question. This disruption underscores the need for providers to reach beyond the federal requirements, ensuring compliance with the spirit of the No Surprises Act while prioritizing revenue cycle performance.
How to Move Forward: Key Strategies for Providers
In the face of federal uncertainty, revenue cycle leaders can adopt several strategies to reduce surprise billing and strengthen their operations [2]. Additionally, now is an ideal time to consider outsourcing medical billing services to a trusted medical billing agency that can navigate these complexities on your behalf.
Update Payer Inventory
Providers should review their existing payer contracts and consider expanding their in-network participation with additional health plans. Diversifying payer relationships can increase patient volume while reducing the likelihood of out-of-network billing disputes. By strategically managing their payer inventory, providers can position themselves for growth while minimizing financial risks.
Improving Relationships with Health Plans
Strong relationships with health plans are essential for navigating the complexities of billing and reimbursement. Proactive engagement with payers can help providers understand plan requirements, streamline administrative processes, and resolve disputes with maximum efficiency. These relationships can also open doors to better contract terms and reimbursement rates, enhancing financial sustainability.
Conducting Operational Reviews
A comprehensive operational review can help providers identify gaps in their current revenue cycle processes and also implement workflows that align with the No Surprises Act, regardless of federal actions. This type of review includes evaluating billing practices, claims appeals, authorization procedures, and patient complaint management. By addressing potential challenges proactively, providers can improve operational efficiency and ensure compliance with both state and federal laws.
Assessing Internal Resources
Providers must evaluate their staffing levels, training needs, and outsourcing strategies to meet the demands of the No Surprises Act. This could involve hiring additional staff, evaluating workflows, or investing in training programs. A thorough resource assessment ensures that a revenue cycle department has the capacity to comply with regulations while maintaining operational efficiency.
Outsourcing Medical Billing
Given the complexities of the No Surprises Act and the disruption of federal layoffs, many providers are looking to outsource medical billing services to manage their revenue cycle. Partnering with the best medical billing company in USA can help providers reduce administrative burdens and ensure timely reimbursement.
Case Study: Nutex Health’s Proactive Approach
Nutex Health, a Houston-based network of microhospitals, offers a strong example of how providers can take a proactive approach to billing under the No Surprises Act [3]. By working with a third-party vendor to assist with out-of-network claim recovery, Nutex achieved an independent dispute resolution success rate of over 80% in the fourth quarter of 2023. The organization now submits 60% to 70% of billable visits to arbitration each month, realizing significant financial benefits.
“Our proactive approach to arbitration under the No Surprises Act has yielded positive results thus far,” said Nutex Chair and CEO Tom Vo, MD. “We have been able to secure rightful payments for our facilities and providers while continuing to deliver high-quality, accessible care to our communities.”
Nutex’s success highlights the importance of being proactive in the face of regulatory uncertainty. By leveraging external expertise and adopting a strategic approach to arbitration, providers can protect their revenue streams and maintain financial stability.
A Path Forward for Revenue Cycle Leaders
As the future of surprise billing legislation continues to evolve, revenue cycle leaders should look for new strategies and partnerships to expand their capabilities and reach beyond the requirements of the government. Now is an excellent time to start looking for the best medical billing company in USA to ensure financial sustainability and deliver an exceptional patient financial experience. Start your search with 3Gen Consulting today.
References
[1] N. N. Levey, “Trump vowed to end surprise medical bills—the office working on that just got slashed,” Fierce Healthcare, 5 March 2025. Available: https://www.fiercehealthcare.com/regulatory/trump-vowed-end-surprise-medical-bills-office-working-just-got-slashed.
[2] M. Reay, “Key strategies for healthcare providers implementing the No Surprises Act,” Bakertilly, 27 July 2023. Available: https://www.bakertilly.com/insights/providers-no-surprises-act.
[3] A. Condon, “Health system’s ‘proactive’ arbitration strategy under the No Surprises Act yields strong results,” Becker’s Healthcare, 5 February 2025. Available: https://www.beckershospitalreview.com/finance/health-systems-proactive-arbitration-strategy-under-the-no-surprises-act-yields-strong-results-ceo.html?oly_enc_id=2015F8566689G4V.
