Background
Included in the No Surprises Act (NSA) is a provision requiring carriers and health plans to report information regarding air ambulance service claims to the Centers for Medicare and Medicaid Services (CMS). The reporting is only expected to be required for two years, and that collected information would be used to issue public reports to assist in understanding what drives the high costs of these services.
Isn’t the first report due in March 2023?
No. There has been confusion over when this reporting requirement will first go into effect, largely because multiple vendor articles have been issued that (incorrectly) reference a March 2023 deadline. We have repeatedly issued content that makes it clear that the reporting will not be due until after final regulations are issued.
Details
The NSA specifically states that this air ambulance reporting will not begin until 90 days after the first full year following the issuance of final rules for the reporting. The proposed rules were issued in 2021; the final rules have yet to be issued. The proposed rules were expected to be finalized in 2021, and so the anticipated deadline for the first report was March 2023. But since the rules have yet to be finalized, the earliest that reporting could be required is March 2025 (if final rules are released before the end of 2023). If your client has received one of the many compliance alerts warning them about a deadline coming up next month, let them know that is not accurate.
Make sure to check out our Health Cost Transparency Guide for Employers available in the Transparency Toolkit on our Resources site. It includes a section that describes the air ambulance reporting requirement. We will update the guide, and keep you posted on developments as soon as final regulations are issued.
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