Implementing a Plan to Comply with the No Surprises Act


The No Surprises Act (NSA) went into effect in January 2022, aiming to protect patients getting necessary care through covered healthcare providers from receiving “surprise medical bills” that create financial hardship and confusion. These bills often occur when a patient receives care at an in-network facility, but one or more providers practicing there are not considered in-network by the patient’s health insurance plan.

To comply with the NSA, hospitals must now meet specific requirements, including publicly displaying disclosures about a patient’s rights regarding surprise medical bills and clarity around the cost of care. A CAH in Arkansas needed help implementing provisions of the NSA, such as disclosure requirements, and the issuance of a Good Faith Estimate (GFE) for self-pay or uninsured patients for certain scheduled services.


The hospital engaged Stroudwater Associates to provide education on the conditions of the NSA, as well as guidance on how to implement the relevant requirements. The hospital’s primary goal was to ensure it was meeting the NSA’s disclosure and GFE specifications.

Stroudwater educated key members of the hospital’s revenue cycle team on the requirements of the NSA and helped them establish processes to address them. Stroudwater scheduled weekly calls to identify the rules relevant to the client, including the development of a workflow to:

  • Provide GFEs to applicable patients
  • Ensure the publication of proper disclosures
  • Create a strategy for engagement with other providers to provide accurate cost estimates to patients


Stroudwater provided the education, assistance, and data it needed to comply with disclosure requirements and develop processes to help patients understand their cost of care for scheduled services.

The Hospital contracted with Stroudwater as it did not have the resources to develop appropriate NSA disclosures for patients or a workflow for addressing GFE requirements.

“We were challenged with the No Surprises Act compliance as we have limited staff. After we contacted Stroudwater, we went step by step with verifiable actions and they answered any questions that came up,” said William Craig, Chief Financial Officer, Howard Memorial Hospital. “I feel that as a facility partnering with Stroudwater helped us meet our goals.”