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Commonwealth Fund Release Interactive Map of Federal, State Governments Role Relating to No Surprises Act

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The No Surprises Act, signed into law in 2020, went into effect for most consumers enrolled in individual and group health insurance plans on January 1, 2022.

The Commonwealth Fund released an interactive map which summarizes the roles of the federal and state governments on various aspects of the No Surprises Act, including enforcement, specified state laws for payment determination, the use of external review for surprise-billing cases, and the patient–provider dispute resolution process.

The federal law builds on state laws enacted in 33 states, extending protections to consumers in self-funded plans that states cannot regulate and extending protections for air-ambulance services, where federal law restricted states’ ability to act. Implementation and enforcement of the No Surprises Act involve both federal and state governments. Many states are sharing enforcement responsibility with the federal government, sometimes with a collaborative enforcement agreement.

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