Since the No Surprises Act was signed into law in 2020, the Department of Health and Human Services has published several rules with respect to the Act, leaving many unanswered questions. With the Act taking effect this month, forums are now being held to educate providers on the new law, which curtails surprise medical bills from out-of-network providers.

The Act went into effect on January 1, 2022, and is generally accompanied by civil money penalties in cases of non-compliance. A few weeks into this new and complex law, there are still many outstanding questions left for the Department of Health and Human Services and Centers for Medicare and Medicaid Services (CMS) to address.

CMS held its first Open Door Forum on the Act with Eugene Freund, MD, and Elyse Mowle, PhD, on January 26, 2022. The forum was a great educational event with hypothetical questions and answers posted in a presentation by CMS, which can be accessed at In addition, CMS has good provider requirements and resources at

During the forum, CMS stated that it will hold more educational events on the No Surprises Act soon. Providers can sign up for email updates on these forums at

For questions or assistance with compliance with the Act, please reach out to any of Greensfelder’s Health Care attorneys.