No Surprises Act Includes Directory Update Requirement
By Joey Berlin

In addition to resolving payment disputes over out-of-network medical care, the federal No Surprises Act (NSA) aims to make sure health plans’ practitioner directories stay up to date, and part of that aim puts an onus on physicians.

The congressional surprise-billing law requires physicians and other practitioners to notify insurers in a timely manner of “material changes” to the information that appears in the health plans’ directories. Health plans, in turn, are required to establish a system to verify the accuracy of the information in their directories every 90 days – which likely means they’ll require physicians to verify their directory entries during that time frame even if there are no changes to report.

Texas Medical Association staff have received reports of health plans beginning this process and say complying with this requirement will take time and effort. Methods of verifying no change in the status of your directory entry, or submitting potential updates, likely will require electronic-portal submission of the information to the health plan, rather than via mail or fax.

TMA and the American Medical Association offer resources for you to keep up with the ins and outs of the NSA. Check out TMA’s list of resources on the law and TMA’s Surprise Medical Bills page, which includes information on both federal surprise-billing law and state law.

There you will also find the AMA’s Preparing for the No Surprises Act toolkit, which includes information on operational challenges physicians must address to comply with the law, timetables for the independent dispute resolution process used to settle payment disagreements between physicians and health plans, and more. The toolkit notes that AMA will provide more information on the new provider directory requirements “in future AMA resources.”

Last Updated On

February 10, 2023

Originally Published On

July 25, 2022