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Case Study

Helping hospital systems know how to implement the No Surprises Act

Executive Summary

Many provisions of the No Surprises Act – which went into effect on Jan. 1, 2022 – required extensive training, education, and communications for healthcare organizations to demonstrate compliance. Most chief compliance officers anticipated obstacles as they prepared their healthcare organizations to implement the complex law.

The rollout has not been easy for many hospital systems. It was tough for CCOs to know about all the regulatory changes in the complicated law and what to do to comply with it.

YouCompli resources, such as relevance questions and model policies and procedures, helped CCOs know how to best prepare their organizations.

YouCompli helped hospital systems know any and all regulatory changes created by the No Surprises Act and what they needed to do for a successful implementation.

The Challenge

Most chief compliance officers expected obstacles as they prepared their healthcare organizations to implement the No Surprises Act. Many provisions of the complex law – which went into effect on Jan. 1, 2022 – required extensive training, education, and communications for healthcare organizations to demonstrate compliance.

The law aims to simplify billing by increasing transparency and to decrease unexpected bills for patients. But the rollout has not been easy for many hospital systems.

“I applaud the goal of the bill, but the path to get there is burdensome for hospitals,” said the director of corporate compliance and privacy officer at an East Coast health system.

She summarized the challenges hospital systems face in complying with the No Surprises Act.

“If we don’t inform patients and get their consent to bill them, hospitals are stuck with the unpaid balances,” she said. “Those unpaid balances have always been a risk, of course. But now we have extra work to get to the same place – trying to figure out what the charges are and making sure patients know what they are. And we’ve got to get their approval to charge when necessary.”

Knowing what would change and how to comply was overwhelming, given the scope of the No Surprises Act. That’s where YouCompli came in.

The Solution

Knowing which changes were coming – and what to do about them – was time consuming for this CCO. And the timing could not have been worse. CCOs like her were preparing for the No Surprises Act during yet another pandemic surge. It was tough for CCOs to know what do, particularly when their colleagues were focused on patient care and not easily accessible to weigh in.

YouCompli provided several resources for knowing how to prepare healthcare organizations to comply with provisions of the No Surprises Act.

For example, the succinct relevance questions written by YouCompli analysts helped CCOs know whether changing regulations pertained to their organization. The relevance questions also guided CCOs to know what questions to ask of their colleagues.

The East Coast director of corporate compliance and privacy officer found the relevance questions helpful. “You can determine very quickly if you need to do anything further with a reg change or not,” she said.

Also, YouCompli’s model policies and procedures helped her know what to do about the changes. Her organization’s Revenue Cycle department found these resources especially valuable.

“I worked closely with our Revenue Cycle folks; there was a lot of back and forth with them,” she explained. “They were really the ones principally responsible for implementation of the No Surprises Act.”

Her Revenue Cycle colleagues appreciated having all the model policies and procedures in one place.

“There was no, Do we need to do this, do we need to do that?” she said. “It was like having a cookbook and a recipe to follow.”

Director of Corporate Compliance and Privacy Officer an East Coast health system

With YouCompli helping her know how to comply with the No Surprises Act, she was able to deliver more value to the entire hospital system.

The Impact

“With the No Surprises Act, YouCompli resources were so valuable for helping us get up to speed with that big change,” she added. “YouCompli was the safeguard; it was my safety net.”

She said having all the resources available in one place saved time. And with YouCompli, she knew whether a change was relevant without dedicating hours to reading regulations.

“All the consents and notices were right at my fingertips, all together,” she said. “I just had to open the notice, and there was everything we needed. It really saved hours of work.”

She said using YouCompli makes her job easier: “It’s like you have an extra person doing research that’s not on your staff – and that you don’t have to do performance evaluations for or pay benefits for.”

YouCompli also makes demonstrating compliance easier for CCO Scott Borsuk of Western Maryland Health Systems. He said YouCompli helps him stay ahead of fines and demonstrate the value of what the compliance function brings to the larger organization.

Both are crucial for complex regulatory changes like the No Surprises Act. Borsuk also appreciates how YouCompli can generate an end-to-end audit trail, tracking all compliance decisions and activity. If needed, YouCompli can easily prove how his organization has complied with a change.

“I’d look within YouCompli, figure out what changed, when the change was sent to us, and there’s a whole audit trail,” Borsuk said.

He said YouCompli helps him easily know who sent a change, how his organization implemented it, and how the charge master was updated. Borsuk added that YouCompli resources help him know about subtle changes, like coding changes or diagnoses changes in a local coverage determination, or LCD.

“If there’s a change made in an LCD, the burden is on us” to know about it and comply with it, Borsuk explained.

Whether it’s a coding change or extensive regulatory modifications like the No Surprises Act, YouCompli helps CCOs know what’s changing and how to manage it. By helping CCOs know what to do and how to do it, the comprehensive YouCompli solution helps them elevate their hospital system’s compliance function.

“In the compliance world, we all seek peace of mind because of the burdensome, constantly changing regulatory environment,” said the East Coast compliance officer. “That’s what keeps compliance officers up at night: ‘Did I miss some- thing?’ With YouCompli, somebody has your back.”

YouCompli has been a critical resource for hospital systems to know how to successfully implement the No Surprise Act. The law is a work in progress, and YouCompli will continue to support healthcare organizations in knowing what’s changing and how to comply.

Find out how you can use YouCompli to know about regulatory changes that affect your organization and make sure those regulations are translated into policies and procedures that affect patient care.
YouCompli customers have access to notifications about changes to regulations, resources to inform policy and procedure updates, and tools to track compliance.
Download a PDF of the YouCompli Case Study