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Stethoscope on dollars Looking at the current state of the health care industry, one would be justified in expressing concern over future dependence upon past “averages” to determine reimbursement rates. (Photo: iStock)

Editor’s note: This is the final installment of a three-part deep-dive dive into the nuances of this much-heralded piece of health care reform. Check out the first and second parts.  

The last, and perhaps most relevant factor for mediator consideration under the No Surprises Act is past contracted rates, and median in-network rates. On the positive side, this will hopefully prevent the billed charges from being deemed the “starting point” or misrepresented as what is “usually paid” by benefit plans. Generally speaking, states that have implemented regulations limiting surprise balance bills that take such median rates into consideration generally see smaller amounts being paid than in States that do not take median rates into consideration.

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