WSHA comments on BBPA rulemaking

December 13, 2022

Last week, WSHA submitted comments to the Washington State Office of the Insurance Commissioner’s (OIC) CR-102 draft rule to implement E2SHB 1688, which aligns portions of the state’s Balance Billing Protection Act with the federal No Surprises Act.

WSHA has been working with OIC to refine the definition of “outpatient hospital department” used in the rule. The definition in the proposed rule reflects WSHA’s earlier input, but added a provision that could include non-hospital sites of a hospital or health system if they share a tax ID number with the hospital. WSHA checked with member hospitals and determined sharing of a tax ID was not uncommon and would impact several hospitals and systems. WSHA and several impacted members submitted comments requesting that reference to tax ID be stricken in the final rule. The final rule is expected to be released within the next several weeks.  (Andrew Busz,


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