WEDI No Surprises Act Provider Survey Results

The No Surprises Act was signed into law on December 27, 2020, as part of the Consolidated Appropriations Act, 2021 (Public Law 116-260). The requirements for providers to issue Good Faith Estimates (GFEs) to uninsured and self-pay patients were put into place on Jan 1, 2023. Considering that several years have now passed WEDI sought to assess provider experiences with the implementation of these requirements. Our objective was to gather insights that could inform the Departments’ approach as they advance additional provisions of the No Surprises Act (NSA) for insured patients—specifically, the issuance of GFEs by providers to health plans and the subsequent delivery of Advanced Explanations of Benefits from health plans to patients.

The survey was conducted in February and March 2026. It was open to all provider types. We received 38 responses. Respondents were fairly evenly distributed among hospitals, health systems, group practices, and single clinician practices. The respondents included small, medium, and large organization by billing volume. Although the low volume of responses may not produce reliable reflections of the industry at large, we believe that the individual responses nonetheless shed important light on issues facing some providers.

Most respondents indicated that they have a process to provide patients with an estimate of costs before services are rendered, though not all indicated that they provide those estimates to insured patients. Most reported that they are aware of the NSA requirements for patient GFEs. When asked how they generate their estimates, some said they use specific software and others generate them manually with the help of spreadsheets and other tools.

Most of the respondents, when asked about the difficulty in issuing GFEs, found the GFE process difficult or very difficult. Some of their specific difficulties with issuing GFEs included:

• “Ensuring accuracy of estimates prior to service without knowing exactly what will be performed at the time of the visit; Administrative burden requiring hiring additional resources”
• “more FTEs would be required to implement estimates for all insured patients; Level of complexity for non-clinical staff to determine which clinical codes to include in patient estimate “
• “It is very time consuming and puts a huge burden on our front desk.”
• “Not many patients wanted to pay out-of-pocket. Even when offered the opportunity to pay less or a very tiny amount, they prefer not to receive services.
• “For providers, it's very difficult to obtain accurate benefits and knowing what will vs. will not be covered by the patient's insurance(s). We do our best with tools available, but payers really need to be providing this information for situations when we need to incorporate into our estimates for insurance patient requests.”

Most respondents had not received any estimates from co-providers, nor had they given any estimates to other providers. Some comments indicated that they felt the exchange of estimates would be quite complex or nearly impossible.

Half of the respondents indicated that they received GFE requests from individuals who were not yet their patients, and most received requests from patients before they scheduled services (i.e., price-shopping for estimates). About half of the respondents said at least some of these requests resulted in the patient coming in for services.

Regarding patient feedback, most indicated that it was mixed between positive and negative, with many receiving further questions from patients regarding the accuracy of the estimates, taking up staff time. Most respondents indicated that their estimates were close or very close to the final bill. Some interesting individual specific comments were:

• ”The $400 threshold for accuracy is arbitrary and should be a percentage rather than a flat dollar amount. Please do a survey about pending legislation for insured estimates as there are a lot more complexities to provide feedback on.”
• “No matter how many times you explain it is a price based on what we know right now, things change during procedures and additional codes are billed, patients still complain about having to pay more than what their GFE stated. Also, right now we still do not have a report to show us our variance from the estimate to what was billed, nor a compliance report, so it is hard to determine if we are doing well or not.”
• “We intentionally used the highest end on the estimate to be sure the majority of actual bills came back lower than the estimate. It was important to create a fair assessment of the billing for patients.
• “When patients realized that they are not covered by insurance, they will have to pay out-of pocket. Most of them decide not to continue services as they cannot afford it. Others decide to have treatment once a month so they can afford it. Even though a payment plan is offered they refused to accept it.”