By Ed Marasco, MPM, CMTE, EMT-P (Ret.) *


NSA Update Jan 2024

The last six (6) months have been a bit of a roller coaster for those around the industry who are dealing with the impact of the Federal No Surprises Act (NSA). This period has been marked by great uncertainty, suspension of key elements of the process and another wave of changes. All of these developments have resulted in delays in the resolution of claims and delays in payments for Providers. Nonetheless, the Departments were compelled to make a change to the Fees associated with the IDR process to accommodate the statutory requirements of the NSA and to respond to the needs of the IDR entities. This process has not been an easy one because the Departments received many comments from interested parties as well. Another rule addressing the fees was published in the Federal Register on December 21, 2023. On Friday January 12, 2024, the Departments updated the NSA website to reflect the upcoming changes to the fee structure. The key elements of the fee changes include:



The new Administrative Fees will be $115 per party per dispute. This is a substantial increase over the $50 per party per dispute that had been in effect. The change and new amount were derived by a computation based on the cost of providing the necessary support to the IDR process . . . essentially the cost of administering the NSA regulations. As those familiar with the process will recall, these fees are NOT refundable in any fashion.



The Independent Despite Resolution (IDR) Entity fees are set at between $200 and $840 for single determinations and between $268 and $1,173 for batched determinations. These are the fees paid to the IDR Entity, by both parties, to cover the cost of the IDR process. The NSA web site includes more detailed information about the specific fees for each circumstance and the fees for each IDR Entity.


The effective date for the Fee Changes will be January 22, 2024. That is to say that the new rates will apply to disputes initiated on or after January 22, 2024, regardless of the date of service of the claim itself. The NSA web site and the body of the Federal Register notice offer additional background and detail. Stay tuned for more information on changes to the NSA related processes and updates from the QMC team as we maneuver the shark infested waters of the NSA.


*Ed Marasco is QMC’s Vice-President of Business Development and a veteran healthcare provider and administrator with over 40 years of experience in emergency medical services, reimbursement, and consulting.


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