This second report focuses largely on updating pre-NSA trends in claims data presented in the first report. Surprise bills are difficult to cleanly identify in claims data; therefore, we generally examine trends in all OON bills associated with emergency items and services (regardless of network status) or non-emergency items and services furnished with respect to a visit at an in-network health care facility, which we define as “potential surprise bills.” This report updates trends in OON bills and potential surprise bills as well as trends in market consolidation and concentration. It also identifies factors associated with high health care costs for families. In general, in 2021, trends in potential surprise bills continued the decline seen since at least 2012.
This report also describes discussions conducted with interested parties such as health care providers, private health plans and issuers, and patients. Both providers and private health plans and issuers reported that one of the objectives of the law appears to have been achieved, noting that patients are no longer caught in the middle of payment disputes between OON providers and private health plans and issuers with respect to items and services to which the NSA applies. Providers highlighted the cost burden of implementing the NSA. Patients, even those who had experienced surprise bills in the past, had limited awareness of the NSA and its consumer protections. Some patients, however, reported continuing problems with unexpected medical bills, although it was unclear to what extent these bills were surprise bills prohibited by the NSA. Providers also noted unexpected costs of implementing the NSA and concerns about a lack of transparency around QPA calculations.
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