Testimony On HB 3848: Ambulance Network Adequacy

TAHP is opposed to HB 3848 as filed but would be neutral with the addition of surprise billing protections and assurances that network adequacy waivers would be available in the event that contracting at affordable market rates is not possible.

Texans are currently protected from surprise billing for hospital and physician services through SB 1264 (86th) and the federal No Surprises Act. However, there are no existing protections for ambulance surprise billing under state or federal law. Although strengthening ambulance network adequacy may have some benefits, it fails to address the root problem of surprise billing or balance billing. In fact, evidence shows that simply strengthening a state’s regulatory standards for network adequacy does not protect patients from surprise medical billing. States with the strongest standards for network adequacy often had the highest rates of surprise billing prior to the federal No Surprises Act, as was the case in Texas before the passage of SB 1264. Despite adopting the most stringent network adequacy standards in the country, Texas had some of the highest rates of surprise billing in the nation, if not the highest.

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