Federal regulators were expected to respond to recent pressure from Congress by advancing long-delayed transparency rules for payers and providers.
The No Surprises Act (NSA), enacted in 2020, included several requirements that CMS has not yet implemented, including:
Good faith estimates (GFEs) from providers to commercially insured patients
An advanced explanation of benefits (AEOB) from payers to all patients before they receive care
The increasing pressure from legislators likely means rules for both GFEs and AEOBs will come in 2026, said Shawn Stack, director of perspectives and analysis for HFMA.
The ways hospitals and health systems can prepare for them include:
Getting an all-inclusive good faith estimate in place with all clinicians
Checking how their vendors can help create good faith estimates and AEOB processes
In response to new audit findings, the Health Resources and Services Administration (HRSA), which oversaw Provider Relief Fund allocations, said it will conduct post-payment reviews of hospitals to assess compliance with a ban on balance billing.
HRSA said it will review whether hospitals that received PRF monies during the COVID-19 pandemic met the terms and conditions, including a prohibition of balance billing of such patients.
The HRSA plan followed an Office of Inspector General finding that 17 of 25 hospitals it examined did not comply or may not have complied with requirements to avoid balance-billing COVID-19 patients.
Among the 17 hospitals found potentially noncompliant, HRSA intends to request that they refund patients, which OIG linked to billings of more than $637,000.
The PRF distributed nearly $146 billion between 2020 and 2023, with funding eligible to be used to cover healthcare-related expenses or lost revenue attributable to COVID-19.
*Includes five hospitals from the improperly billing category
Source: Seventeen of Twenty-Five Selected Hospitals Did Not Comply or May Not Have Complied With the Provider Relief Fund Balance Billing Requirement, HHS OIG, Sept. 23, 2025.
Three targets provide employers’ biggest healthcare savings
An alliance of large employers has identified three approaches that have provided its member companies with the largest healthcare savings.
The Health Transformation Alliance (HTA), a cooperative owned by about 80 U.S. companies, including JP Morgan Chase, Intel, Comcast, Boeing and Marriott, found the initiatives that have saved employers the most in healthcare expenditures include:
Switching from fully insured to use of third-party administrators (TPAs)
Shifting to a full pass-through pharmacy benefit manager
Pushing payment integrity
The TPA shift drives the biggest savings because it provides more transparency on prices and quality, said Rob Andrews, CEO of HTA.
His organization is pushing legal prohibitions on contractual gag clauses between providers and payers. Every company in HTA has been blocked by such clauses when trying to steer enrollees to higher-quality and lower-cost providers, Andrews said.
Amount CMS will distribute in 2026 in Rural Health Transformation Program funds based on its assessment of coming state plans for the money. Read more.
Crucial Dates
LEGISLATIVE
Oct. 30: Medicaid and CHIP Payment and Access Commission public meeting
REGULATORY
Nov. 1: Comments due for OSHA proposed rule to remove certain COVID-19 safety requirements for healthcare workers in 2025
Nov. 5: Deadline for states to submit a plan to CMS for funds from the Rural Health Transformation Program
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