States with external review processes that cannot accommodate No Surprises Act compliance matters may refer these matters to the Department of Health and Human Services’ external review process or use the accredited independent review organization, the Centers for Medicare & Medicaid Services said in guidance issued last week. Under the Affordable Care Act, consumers can appeal health plan decisions to an external review process, which effective this Jan. 1 includes health plan decisions related to NSA surprise billing and cost-sharing protections. 

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