Improving Financial Communication and Compliance Under the No Surprises Act

Regulatory review: This article reflects federal No Surprises Act requirements and related operational guidance applicable as of 2026. Because federal guidance, payer policies, and state requirements may change, healthcare organizations should verify current requirements before implementing compliance or billing workflows.

The No Surprises Act has fundamentally changed how healthcare organizations manage patient financial communication, out-of-network billing, and cost transparency. While the legislation was introduced to protect patients from unexpected medical bills, its long-term impact extends well beyond compliance. It has reshaped financial workflows across scheduling, registration, billing, and revenue cycle management.

The Centers for Medicare & Medicaid Services (CMS) provides guidance and resources for providers implementing the No Surprises Act to help healthcare organizations apply many of the federal patient protections established under the law.

While the law establishes the regulatory framework, each practice must translate applicable requirements into consistent operational workflows.

In my experience working with independent medical practices, compliance itself is rarely the greatest challenge. More often, practices struggle with creating consistent financial workflows that every department follows in the same way. Smaller practices often face this challenge because a single employee may perform scheduling, registration, and billing functions, while larger organizations must maintain consistency across multiple departments, locations, or provider groups.

Without standardized processes, practices are more likely to provide inconsistent financial information, create unnecessary administrative burden, and experience billing disputes or patient dissatisfaction.

Today, the No Surprises Act should be viewed as an operational framework rather than simply a regulatory requirement. Like any operational process, financial communication workflows should have clear ownership so policies are reviewed, staff education remains current, and procedures evolve as regulatory requirements change.

Who this article is for: This guide is intended for physicians, practice owners, practice administrators, office managers, billing professionals, revenue cycle leaders, and other healthcare professionals responsible for patient financial communication and operational compliance.

Important scope distinction: Not every No Surprises Act requirement applies to every medical practice or service. Federal No Surprises Act protections primarily address emergency services, out-of-network air ambulance services, and certain non-emergency services furnished by out-of-network providers at specified in-network facilities.

Independent physician offices may be more directly affected by Good Faith Estimate requirements for uninsured or self-pay patients and by related financial communication responsibilities. Each organization should determine which provisions apply to its services, setting, and patient population.

Key Takeaways

• The No Surprises Act now functions as an operational framework rather than solely a compliance requirement.
• Financial discussions should begin before care is delivered.
• Standardized workflows reduce billing disputes and administrative burden.
• Consistent documentation supports both compliance and revenue cycle performance.
• Staff education strengthens long-term operational consistency.
• Continuous monitoring helps identify workflow issues before they become compliance problems.

The No Surprises Act Changed More Than Billing

Although the legislation is often associated with balance billing restrictions, its operational impact reaches much further.

From an operational perspective, the law has increased the importance of addressing network participation and applicable patient financial protections before services are delivered. Scheduling teams may verify insurance participation before appointments are confirmed. Registration staff communicate applicable financial information. Billing personnel prepare required estimates or disclosures. Revenue cycle teams maintain documentation supporting those communications.

The practices I’ve worked with most successfully integrate these responsibilities into routine scheduling, registration, and billing workflows instead of treating them as isolated compliance tasks managed solely by the billing department.

One common issue I see is that each department believes another team has already discussed financial responsibility with the patient. Establishing clear responsibilities for every stage of the patient journey helps eliminate those communication gaps.

For example, scheduling staff may verify insurance participation before an appointment is confirmed, registration reviews anticipated patient financial responsibility during check-in, and billing prepares required estimates or financial documentation. Although each department performs a different function, the workflow remains coordinated across the patient experience.

When every department follows the same process, patients receive more consistent financial information and staff spend less time resolving misunderstandings after services have been provided.

Financial Transparency Begins Before the Visit

One of the most significant operational changes involves communicating expected costs before care is delivered.

For individuals who are uninsured or are choosing not to use insurance to pay for care, Good Faith Estimates provide advance information about reasonably expected charges for scheduled or requested items and services. Preparing these estimates requires coordination between scheduling staff, clinical teams, and billing personnel so the practice can identify the expected services, calculate anticipated charges, and provide the estimate within applicable timeframes.

Developing an effective Good Faith Estimate workflow involves more than generating the estimate itself. In practice, the estimate process often depends on accurate scheduling information when the appointment is created. Incomplete appointment details or changes to the planned services can affect both estimate accuracy and the practice’s ability to provide timely financial information.

Practices should establish procedures that comply with applicable Good Faith Estimate requirements for gathering accurate scheduling information and identifying the items and services reasonably expected to be furnished. They should also establish procedures for determining when changed circumstances require a revised estimate and documenting when estimates or updated financial information were provided.

Developing reliable estimate workflows also benefits insured patients. While insurance coverage varies, practices that verify benefits, explain deductibles and coinsurance, and discuss potential out-of-pocket expenses early often experience fewer billing disputes after treatment.

Even when a Good Faith Estimate is not required, many practices find that discussing deductibles, coinsurance, and anticipated out-of-pocket costs before the visit improves patient understanding and reduces billing questions after claims are processed.

Financial transparency is most effective when it becomes a standard part of every patient encounter rather than an exception reserved for complex cases.

Managing Out-of-Network Services Requires Consistency

The No Surprises Act changed how affected providers, facilities, health plans, and issuers manage out-of-network billing in specific protected situations, including most emergency services, out-of-network air ambulance services, and certain non-emergency services furnished by out-of-network providers at specified in-network facilities.

From an operational perspective, the emphasis should be on consistent verification, documentation, and communication rather than reacting after claims have been processed.

Organizations that furnish services potentially subject to federal surprise-billing protections should establish standardized procedures for confirming network participation and identifying protected situations. They should also establish procedures for documenting required patient communications and maintaining records that support billing decisions.

Physician practices that are not involved in covered facility-based services should still establish reliable procedures for network-status communication and any Good Faith Estimate obligations that apply to their uninsured or self-pay patients. Inconsistent processes often lead to avoidable administrative work, delayed claim resolution, and increased patient confusion.

These workflows reduce uncertainty for both patients and staff while helping practices maintain compliance throughout the revenue cycle.

Written policies alone are not enough. Staff must apply those policies consistently across each stage of the patient financial experience.

Common Operational Mistakes When Implementing the No Surprises Act

In my experience, practices are more likely to encounter operational challenges because of inconsistent workflows than because they misunderstand the law itself. Standardizing financial communication across departments often prevents many of the problems that lead to patient complaints, billing disputes, and unnecessary administrative work.

• Waiting until the day of service to discuss patient financial responsibility.
• Performing inconsistent insurance verification before appointments.
• Failing to document financial discussions or estimate delivery.
• Allowing different staff members to communicate financial policies differently.
• Treating compliance as the billing department’s responsibility rather than a practice-wide operational process.
• Reviewing financial policies only after complaints or compliance issues arise.

Operational Areas Most Affected

Compliance depends on multiple departments working together rather than relying solely on the billing office.

Department	Operational Responsibility
Scheduling	Verify insurance participation and identify potential financial responsibility before appointments.
Registration	Communicate applicable financial policies, provide required notices or disclosures when assigned, and document patient financial discussions.
Billing	Prepare applicable estimates and billing documentation, support compliant claim and patient-billing processes, and monitor reimbursement or dispute trends.
Revenue Cycle	Resolve disputes, maintain documentation, and monitor compliance trends.
Practice Leadership	Develop policies, oversee staff education, and ensure workflow consistency.

Clearly defined responsibilities reduce confusion and create a more predictable financial experience for both patients and staff.

Staff Training Supports Long-Term Compliance

Because financial regulations continue to evolve, staff education should remain an ongoing operational priority.

Effective training programs should reinforce:

• Accurate insurance verification and financial communication.
• Preparation and documentation of Good Faith Estimates when required.
• Standardized handling of out-of-network services.
• Consistent documentation supporting financial disclosures.
• Procedures for resolving billing questions and payment disputes.

When employees understand both the regulatory requirements and the operational reasons behind them, compliance becomes part of everyday workflow instead of a reactive process. Periodic refresher training and regular policy reviews also help maintain consistency as staff members change roles, new employees join the practice, and payer requirements evolve.

Documentation Protects Both Patients and Practices

Clear documentation plays an essential role throughout the patient financial experience.

During compliance reviews, payer inquiries, or patient billing disputes, documentation often becomes the primary evidence that required financial communications occurred. Practices should maintain records of insurance verification, financial discussions, estimates provided, and patient acknowledgments when applicable.

They should also maintain records of any updates communicated throughout the course of treatment. Thorough documentation supports billing accuracy while providing valuable protection if reimbursement questions or patient disputes arise later.

Strong documentation also improves internal consistency by allowing staff to quickly understand previous financial conversations without relying on incomplete notes or verbal communication. This becomes especially valuable when patients reschedule appointments, speak with multiple employees, or return for ongoing treatment, where consistent financial communication helps reduce confusion and duplicate work.

Compliance Should Be Monitored Like Any Other Operational Process

Maintaining compliance requires ongoing evaluation rather than occasional policy reviews.

Practice leadership or another designated operational leader should periodically review estimate accuracy, billing disputes, patient complaints related to financial responsibility, reimbursement trends, documentation quality, internal workflow consistency, and staff adherence to established financial policies. Assigning clear responsibility for these reviews helps ensure process improvements continue as regulations, payer policies, and practice operations evolve.

Routine internal reviews also provide opportunities to update policies as payer requirements and federal guidance continue to evolve.

Viewing compliance as a continuous process of evaluation and improvement allows practices to strengthen financial performance, enhance the patient experience, and adapt more effectively as regulatory requirements evolve.

Although the No Surprises Act establishes federal patient protections, some states have additional surprise billing laws or financial disclosure requirements. Practices should evaluate both federal requirements and applicable state regulations when developing financial policies and operational workflows.

Practices should also consult qualified legal counsel or compliance professionals when developing or substantially revising policies related to federal or state surprise billing requirements.

Frequently Asked Questions About No Surprises Act Compliance

Putting the No Surprises Act into Practice

The No Surprises Act is now an established part of the healthcare regulatory environment rather than a newly implemented law. For organizations subject to its requirements, long-term success depends on translating applicable protections into clearly assigned procedures, reliable documentation, and coordinated patient financial communication.

In my experience, practices adapt most successfully when they do not treat compliance as a separate administrative project. Instead, they assign responsibilities across the patient journey, communicate applicable financial information before care, document important interactions, and coordinate billing after services are furnished. This approach strengthens compliance, reduces preventable administrative work, and creates a more consistent financial experience for patients and staff.

About the Author

Jennifer Blevens-Smith is the founder and principal consultant of Integral Clinic Solutions. With more than two decades of experience supporting independent medical practices, she helps physicians, practice administrators, and healthcare leaders strengthen credentialing, payer contracting, revenue cycle operations, compliance workflows, and practice management. Her work focuses on translating complex healthcare requirements into practical operational processes that improve consistency, reduce administrative burden, and support long-term practice success.

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