This third report extends trends in claims data in this series into 2022, the first year post-NSA implementation. In 2022, the prevalence of out-of-network bills declined 15 percent for emergency services and 11 percent for non-emergency services furnished at in-network facilities relative to 2021. Compared to the baseline of 2019 (which was both prior to the COVID-19 pandemic and enactment of the NSA), there was a 24 percent decline in OON bills for emergency services at any facility and a 17 percent decline in OON bills for non-emergency services furnished at in-network facilities in 2022. Additionally, although OON payments remained higher than in-network payments for emergency services on average, the gap between OON payments and in-network payments narrowed over time, and for non-emergency services at in-network facilities, average OON payments fell below average in-network payments in 2022.
The report also includes an initial analysis of data on completed federal Independent Dispute Resolution (IDR) disputes over OON payment rates between providers and private health plans and issuers. In 2023, providers won around 80% of IDR determinations over OON claims and around 85% of IDR determinations over OON air ambulance services.
This report also includes an analysis of trends in consolidation in health care markets, though it does not attempt to estimate specific effects of the NSA. Over the past decade, hospital and physician markets have become more consolidated through mergers and acquisitions. It is too early to tell the magnitude and direction of the impact of the NSA on negotiations between providers and private health plans and issuers.
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https://aspe.hhs.gov/reports/no-surprises-act-report-one
https://aspe.hhs.gov/reports/no-surprises-act-report-two
https://aspe.hhs.gov/reports/environmental-scan-consolidation-health-care-markets
https://aspe.hhs.gov/reports/perspectives-key-stakeholders