Group health plans and health insurance issuers will not be required to submit certain information on air ambulance services by March 31, 2023 (the deadline included in an example in the proposed regulations). The Centers for Medicare & Medicaid Services has informally confirmed that since final regulations have not yet been issued, no reporting is required in 2023.
In September 2021, the departments of Health and Human Services, Treasury and Labor released proposed regulations on the air ambulance reporting requirements under the No Surprises Act. The gathered data would be used to develop a comprehensive public report on air ambulance services.1
Although the proposed regulations had indicated that the first reporting deadline would be March 31, 2023 (for 2022 calendar-year reporting), and March 30, 2024 (for 2023 calendar-year reporting), those deadlines were based on the expectation that final regulations would be issued before the end of calendar year 2021. Final regulations were not issued in 2021 nor 2022.
Assuming final regulations are issued during the 2023 calendar year, then the first report would be due 90 days after the end of 2024 (i.e., March 31, 2025) for the 2024 calendar year, and the report for calendar year 2025 (the second reporting year) would be due March 31, 2026.
1 For more information on the air ambulance reporting requirements, see “Proposed regulations on air ambulance data reporting requirements,” Insider, September 2021.
