Thoughts on Healthcare Markets & Technology
Thoughts on Healthcare Markets & Technology Podcast
Part I: What Federal Billing Transparency Rules Actually Require, What Patients Can Really Do Before a Bill Hits Collections & Where the No Surprises Act & Price Transparency Rules Have Quietly Failed
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Part I: What Federal Billing Transparency Rules Actually Require, What Patients Can Really Do Before a Bill Hits Collections & Where the No Surprises Act & Price Transparency Rules Have Quietly Failed

The viral HIPAA billing claim is wrong. Hospitals do not need your signed authorization before sending a bill to collections. The Privacy Rule explicitly lists collection as a permitted payment activity.

The protection that actually works is Section 501(r) of the tax code. Nonprofit hospitals must make reasonable efforts before any extraordinary collection action. That window runs 240 days from the first billing statement.

The 2026 price transparency rewrite eliminated the estimated allowed amount placeholder. Now a named senior executive must attest the file is true, accurate, and complete. CMS declined to rule out False Claims Act exposure on defective attestations.

The No Surprises Act protected patients from balance billing and created a 15-billion-dollar arbitrage. The top 10 initiating parties drove roughly 70 percent of independent dispute resolution volume in the first half of 2025.

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