A working No Surprises Act checklist for independent practices

The No Surprises Act created real obligations for practices of every size — and most of the coverage focuses on hospitals, leaving independent practices to guess at what applies to them. Here's the working checklist we use with clients.

Good-faith estimates (GFEs) are the core obligation for most practices: uninsured and self-pay patients must receive a written estimate of expected charges before scheduled services. The estimate must be provided within specific timeframes tied to how far ahead the service is scheduled.

Accuracy matters because of the dispute process: if the final bill exceeds the GFE by $400 or more, the patient can initiate a patient-provider dispute resolution process. Estimates built on real benefit verification — not averages — keep you out of that process entirely.

Notice and consent rules apply if you ever deliver out-of-network care at in-network facilities. If that describes any part of your operation, the standard notice-and-consent documentation needs to be part of your intake workflow, with copies retained.

Balance billing protections restrict billing patients for emergency services and certain facility-based care beyond in-network cost sharing. Verify how your specialty intersects with these rules — assumptions here are expensive.

Operationally, compliance lives at the front desk: patient status identification (insured vs. self-pay), estimate generation, and documentation retention all happen at scheduling and intake. Train there, audit there.

This checklist is general information, not legal advice — but it covers the obligations we see practices miss most often. A compliance review of your intake-to-billing workflow closes the gaps quickly.