Surprise Billing Laws: What Massachusetts Physicians Need to Know

Stay Compliant with Federal and Massachusetts Requirements

Federal and Massachusetts surprise billing laws include requirements for patient notice, billing protections, price transparency, and network status disclosures.

Massachusetts physicians must understand both:

• The Federal No Surprises Act (NSA)
• The Massachusetts Patients First Act

While many requirements overlap, federal regulations currently govern most physician compliance obligations.

Key Update

**Massachusetts Enforcement Delayed Until 2027**

Due to advocacy by the Massachusetts Medical Society, enforcement of Massachusetts state notice requirements has been delayed until January 1, 2027.

This delay reduces administrative burden and provides additional time for federal regulations to be finalized.

What You Need to Do Now

Physicians and practices should focus on federal compliance requirements, including:

• Required patient disclosures
• Good Faith Estimates
• Surprise billing protections
• Independent Dispute Resolution (IDR) processes
• Price transparency requirements

MMS Resources and Guides

• Webinar: Understanding Federal and Massachusetts Surprise Billing Requirements (2021)
• High Level Overview of Primary NSA Requirements
• MMS Practice Guide for Surprise Billing and Patient Notice (.pdf)

Massachusetts Patients First Act Resources

• Department of Public Health Resources
  • Notice to Providers on Patients First Law
  • Notice to Patients on Patients First Law

Federal No Surprises Act Resources

• Centers for Medicare & Medicaid Services (CMS) Provider Resources
  • CMS Main Landing Page for “No Surprises Act” Resources
  • Summary of Provider Requirements
  • Overview of Rules and Fact Sheets
    *Includes model disclosures and standardized forms for patient notice and consent and good faith estimates
  • Information about the Independent Dispute Resolution Process
  • CMS No Surprises Help Desk or call 1-800-985-3059
  • No Surprises Act Frequently Asked Questions

This information included and linked to on this page is intended to serve as a general resource and guide. It is not to be construed as legal advice. Attorneys with knowledge of the surprise billing and price transparency laws should be consulted regarding the application of these laws to specific situations.