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Compliance Without Killing Your Billing Workflow

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The NSA didn’t just change how you bill patients, it changed how your whole practice has to operate.

The No Surprises Act (NSA) didn’t just change how out-of-network surgeons bill patients, it transformed how your entire practice must operate. What was once a straightforward encounter now requires consistent NSA screening, Notice & Consent (N&C) management, documentation, and strict timing controls across your revenue cycle.  

Most practices weren’t built for this. And when the workflow isn’t designed for NSA compliance, the consequences are immediate:

  • Missed NSA deadlines
  • Missed opportunities to dispute underpayments
  • Exposure to investigation and penalties for violating NSA, especially for non-emergency surgeries performed at in-network facilities. Increased administrative burden for staff.
  • Reduced cash flow and unstable reimbursement
  • Increased administrative burden for staff

But it doesn’t have to be this way.

At CH Revenue Management Solutions (CHRMS), we help independent, out-of-network surgeons build predictable NSA workflows that reduce administrative friction, strengthen compliance, and use the law to align reimbursement with the care delivered.  With the right system, NSA compliance becomes a controlled process, not a disruptive burden.

Below are the core workflow elements every out-of-network surgical practice needs under the No Surprises Act.

Build a Front-End NSA Screening Process That Works 

A predictable NSA workflow starts with accurate triage that prevents last-minute scrambling.

A successful reimbursement framework begins long before billing. It starts at intake and scheduling, where most compliance failures occur.

Every encounter must be screened to determine:

  • Is the facility in-network or out-of-network?
  • Is this emergency or non-emergency care?
  • Does the NSA apply to this specific encounter?
  • Is Notice & Consent required, optional, or prohibited?

The problem: Many practices rely on inconsistent staff interpretations or outdated procedures.

A front-end NSA screening system eliminates guesswork by flagging NSA-applicable encounters at the time of scheduling. This ensures:

  • Fewer compliance errors
  • Better reimbursement outcomes
  • Reduced clerical workload
  • Stronger eligibility for IDR

Structured front-end processes prevent costly mistakes later.

Standardize Notice & Consent (N&C) to Protect Your Billing Rights

An airtight N&C workflow protects your right to bill appropriately and prevents devastating compliance penalties.

Notice & Consent is one of the most misunderstood requirements of the NSA and one of the easiest places to lose revenue.

Common N&C failures include:

  • Missing mandatory disclosures resulting in exposure to penalties
  • Using outdated or non-compliant forms
  • Collecting consent outside required timeframes
  • Storing forms inconsistently or losing documentation
  • Using consent form under prohibited circumstances

A practice cannot afford this type of variability.
The solution is an airtight, standardized N&C workflow, including:

  • Pre-approved state and federal compliant forms
  • Exact timing protocols for obtaining consent where applicable
  • Staff scripts that explain patient rights clearly
  • Consistent digital storage for audit readiness

If your practice chooses not to pursue balance billing or a N&C is not allowed, the workflow changes:

  • Apply in-network cost-sharing
  • Prepare for a potential IDR claim
  • Track insurer response timing within required NSA windows

Standardization preserves your billing rights, and your revenue.

Integrate NSA Timing Requirements Directly Into Your Revenue Cycle

Missing a date by even one day can eliminate your right to dispute underpayments permanently.

Under the NSA, timing is everything.

Missing a deadline by a single day can permanently eliminate your right to:

  • Dispute an underpayment
  • Initiate open negotiation
  • File for IDR

You must comply with:

  • Strict timelines for open negotiation
  • Defined windows to initiate IDR
  • Reduced patient cost-sharing 
  • Required patient disclosure timeframes

CHRMS integrates these timing requirements into your existing revenue cycle systems with:

  • Automated deadline tracking
  • Encounter-level timing alerts
  • Standardized escalation steps
  • Calendar-based workflows for staff

When timing is built into your workflow, not tracked manually, you minimize revenue loss due to preventable errors.

Turn Documentation Into a Strategic Advantage Instead of a Liability

Better documentation doesn’t just ensure compliance, it directly increases your likelihood of winning IDR.

Under the NSA, documentation is leverage.

Strong documentation protects your:

  • Right to balance bill
  • Eligibility for IDR
  • Audit compliance
  • Case strength in payer disputes

Documentation failures commonly include:

  • Incorrect or incomplete N&C forms
  • Missing disclosure logs 
  • Unrecorded patient plan eligibility checks
  • Incomplete documentation of insurer communications

CHRMS builds documentation systems that create consistent, encounter-level records, including:

  • Digital storage tied to each patient encounter
  • Documentation needed for your practice to enhance success Evidence packets ready for IDR submission
  • Staff checklists to ensure nothing is missed

Good documentation doesn’t just ensure compliance, it improves your likelihood of winning IDR, where providers prevail more than 80% of the time.

Bottom Line: The Right Workflow Makes Revenue Flow

The No Surprises Act is here to stay, and the practices that succeed are the ones that move from reactive compliance to proactive workflows.

With a well-designed NSA workflow:

  • Compliance becomes predictable
  • Staff work with confidence
  • Errors become rare
  • Revenue becomes stable
  • IDR becomes a strategic reimbursement tool

At CHRMS, we help independent, out-of-network surgeons build NSA compliance systems that reduce administrative stress, protect revenue, and ensure you never lose money to preventable workflow gaps.

If you suspect your practice may already be losing revenue due to NSA workflow issues, contact us for a complimentary NSA workflow assessment.

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