CurrentFlorida BluePolicy N/A

No Surprises Act and Transparency — Operational Procedures and Provider Requirements

Describes Florida Blue and Truli for Health operational updates and provider requirements to comply with the No Surprises Act and Transparency provisions, affecting providers, facilities, and commercial plan members.

Policy Summary

PayerFlorida Blue

PolicyNo Surprises Act and Transparency — Operational Procedures and Provider Requirements

Policy CodePolicy N/A

Change TypeOperational update

Effective DateJanuary 1, 2022

Next Review DateN/A

Key ActionUse the Independent Dispute Resolution (IDR) process to dispute out-of-network payment amounts; each party submits an offer and the IDR entity selects the prevailing offer.

SourceLink

POLICY UPDATE CHANGES

No material clinical or coverage changes in this revision.

Jan 1, 2022NSA effective

CommercialPlan scope

72 hoursEstimate requirement

RequiredWritten consent

No Surprises Act Protections & Provider Requirements

No Surprises Act protections and provider requirements

Protections and provider obligations under the No Surprises Act:

Members are protected from balance billing for emergency care, non-emergency care by out-of-network providers at in-network facilities, and air ambulance services from out-of-network providers.

Members are only responsible for in-network cost-sharing amounts (deductibles, copayments, and coinsurance) for services performed in an in-network hospital or ambulatory surgical center by out-of-network providers (including emergency medicine, anesthesia, pathology, radiology, laboratory, neonatology, assistant surgeon, hospitalist, or intensivist services) and for emergency medical conditions from an out-of-network provider or facility unless the member provides written consent for post-stabilization out-of-network billing.

Air ambulance providers are subject to the No Surprises Act rules; ground ambulance services are not covered by these rules.

The No Surprises Act applies to commercial plans (including the Federal Employee Program) and does not apply to Medicare plans.

Policy Summary

PayerFlorida Blue

PolicyNo Surprises Act and Transparency — Operational Procedures and Provider Requirements

Policy CodePolicy N/A

Change TypeOperational update

Effective DateJanuary 1, 2022

Next Review DateN/A

Key ActionUse the Independent Dispute Resolution (IDR) process to dispute out-of-network payment amounts; each party submits an offer and the IDR entity selects the prevailing offer.

SourceLink

On This Page

Trek Health ingests and normalizes Transparency in Coverage data and payer policy updates to give provider organizations a clear view of how commercial reimbursement behaves across markets, payers, and services. Our platform transforms raw payer disclosures into structured intelligence that supports contract evaluation, payer negotiations, and service line strategy. By combining market benchmarks with ongoing policy visibility, Trek helps teams identify variability, risk, and opportunity in commercial reimbursement. The result is faster insight, stronger negotiating positions, and more informed financial decisions.

Required Actions by Providers and Facilities

Prior Authorization

Independent Dispute Resolution (IDR) — use for out-of-network payment disputes

Use the Independent Dispute Resolution (IDR) process to resolve disputes about out-of-network payment amounts. Each party submits an offer for payment to an IDR entity, which selects the offer that best represents the value of the item or service as the appropriate out-of-network payment rate. The party that does not prevail is responsible for paying the IDR administrative fees.

Submit a payment offer to the IDR entity when disputing an out-of-network payment amount.
The IDR entity will select the offer that best represents the value of the item or service.
The losing party must pay the IDR process administrative fees.

Key Definitions

inv-03: Balance billing / Surprise bill — definition and short explanation

DefinitionBalance billing occurs when out-of-network providers bill members for the difference between the provider’s charge and the amount paid by the member’s health plan; an unexpected balance bill is called a surprise bill.

When it appliesOccurs commonly for non-emergency care provided by out-of-network providers at in-network facilities and for certain out-of-network air ambulance services.

Exceptions / scopeProviders may not balance bill for emergency care, or for most services at in‑network hospitals/ASCs performed by out‑of‑network clinicians (e.g., emergency medicine, anesthesia, pathology, radiology, laboratory, neonatology, assistant surgeon, hospitalist, intensivist).

Related termA ‘surprise bill’ is an unexpected balance bill received by a member.

inv-04: Member financial responsibility — member cost-sharing obligations and limits under NSA

Member cost-sharing liabilityMembers are only responsible for in‑network cost‑sharing amounts (deductibles, copayments, and coinsurance) for specified emergency and out‑of‑network services performed at in‑network facilities.

Covered scenariosApplies to services performed in an in‑network hospital or ambulatory surgical center by out‑of‑network providers (including emergency medicine, anesthesia, pathology, radiology, laboratory, neonatology, assistant surgeon, hospitalist, intensivist).

Emergency careMembers are protected from balance billing for treatment of an emergency medical condition by out‑of‑network providers or facilities; post‑stabilization services may be billed only if the member provides written consent.

Air vs ground ambulanceAir ambulance providers are subject to these member protection rules; ground ambulance services are not covered by the No Surprises Act protections.