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CHA commented on the proposed rule detailing the enforcement provisions related to the No Surprises Act (NSA).
In the letter, CHA raises concerns about the promulgation of regulations related to enforcement actions before the full set of regulations required to implement the NSA’s core provisions have been produced.
CHA also offers specific technical recommendations to ensure that providers have an appropriate opportunity to respond to allegations that they are out of compliance with the NSA’s requirements.
Additionally, CHA raises concerns about the calculation of the qualifying payment amount (QPA) in determining a patient’s cost-sharing in the independent dispute resolution process and requests confirmation that providers can refer health plans to the relevant enforcement entity to have the QPA calculation reviewed.
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