Emergency Medicine Billing Built for a Post-No-Surprises-Act World.
Balance billing is banned, IDR disputes are backed up, and reimbursement is under sustained pressure. MedVersify's emergency medicine billing team is built around exactly this reality — for ER physician groups and urgent care alike.
Emergency Medicine Billing Has Structural Pressures Other Specialties Don't
3.4M+
Federal IDR Disputes Filed Since 2022
Cumulative disputes filed under the No Surprises Act's Independent Dispute Resolution process reached roughly 3.4 million through mid-2025, with volume more than doubling year-over-year — far beyond the government's original estimate of about 17,000 disputes a year.
Georgetown University Center on Health Insurance Reforms (2025)
55%
Of an ER Physician's Time Spent on Uncompensated Care
ACEP cites CMS data showing emergency physicians spend an estimated 55% of their time providing care that goes uncompensated, a direct result of EMTALA's unfunded mandate to treat regardless of ability to pay.
American College of Emergency Physicians (ACEP)
2 of 3
Uninsured Acute-Care Patients Treated by Emergency Physicians
Emergency physicians make up just 4% of U.S. physicians but provide roughly two-thirds of all acute care delivered to uninsured patients nationwide.
American College of Emergency Physicians (ACEP)
4×
Facility Fees Grew Faster Than Professional Fees
Between 2004 and 2021, the average ED facility fee grew 531% (to $713) while the average professional fee grew 132% (to $321) — facility charges now run more than double professional charges for the same visit.
Peterson-KFF Health System Tracker
Federal Law and Fee Schedule Pressure Now Shape How You Get Paid
Which is exactly why medical billing done right has to start with specialty-specific knowledge, not a generic claims process.
The No Surprises Act changed who you collect from — and how
Since January 2022, balance billing is banned for out-of-network emergency care and post-stabilization care until a patient can safely consent to transfer. Getting paid correctly now runs through payer negotiation and, when that fails, the federal Independent Dispute Resolution (IDR) process — not the patient.
IDR claims need to be tracked, not just filed and forgotten
With disputes now numbering in the millions and volume still climbing, an IDR-eligible claim can sit for months. Billing that doesn't track IDR status separately from standard A/R loses visibility into a meaningful piece of revenue — though provider win rates on determinations have actually been improving, reaching a reported 88% in the first half of 2025.
Reimbursement is under direct, ongoing pressure
Medicare cut the physician fee schedule conversion factor 3.4% for 2024 and 2.8% for 2025, and the 2026 final rule cuts the facility practice-expense component of common ED visit codes by roughly 20% and critical care codes by roughly 30% — reductions ACEP formally opposed. Billing accuracy has to work harder just to hold reimbursement flat.
Facility and professional billing are two different revenue streams
Emergency physician groups typically bill the professional component separately from the hospital's facility charge — and facility fees have grown roughly four times faster than professional fees over the past two decades. Keeping these correctly separated, and making sure both are pursued, is a structural complexity most generalist billers underestimate.
EMTALA means you bill everyone, but only some of it is collectible
The mandate to treat and stabilize every patient regardless of ability to pay drives high uncompensated care rates. Billing strategy has to maximize what's actually collectible from payers and paying patients while handling the uncompensated share correctly for cost reporting.
E/M level selection draws close payer review
Emergency department E/M codes are chosen based on complexity and resources used, and some payers apply "low-acuity, non-emergent" policies that attempt to downcode higher-level visits after the fact. Documentation has to support the level billed clearly enough to push back on this.
Common Emergency Billing Codes
ED Evaluation & Management Levels
Five mutually exclusive levels billed by medical decision-making complexity, not time — one code per encounter.
Critical Care
99291 covers the first 30–74 minutes of critical care; 99292 covers each additional 30 minutes beyond that. Under 30 minutes total is not separately billable as critical care.
Significant, Separately Identifiable E/M
Applied when an E/M service is billed alongside a procedure on the same encounter — a pattern that draws the same kind of scrutiny in emergency medicine as it does in other procedural specialties.
The Denial Patterns Emergency Groups See Most
Payer Downcoding on Acuity Grounds
Some payers apply blanket "low-acuity, non-emergent" policies to retroactively downcode Level 4 or 5 ED visits, regardless of what the presenting symptoms reasonably warranted at the time.
MedVersify Approach
We document and appeal against the prudent layperson standard the visit was actually assessed under, not the eventual diagnosis.
Stalled or Default IDR Determinations
An IDR-eligible claim sits unresolved for months, or reaches a default determination because a required response deadline was missed on either side.
MedVersify Approach
IDR-eligible claims are tracked on a separate timeline with proactive deadline monitoring, not folded into standard A/R follow-up.
Missing Modifier -25 Support
A same-day E/M and procedure billed together without documentation showing the E/M was a significant, separately identifiable service — the same pattern that draws scrutiny across procedural specialties.
MedVersify Approach
We confirm documentation supports the E/M as distinct from the procedure before submission.
How MedVersify Handles Emergency Medicine Billing
NSA / IDR Eligibility Triage
Every out-of-network emergency claim is flagged for No Surprises Act applicability and tracked separately if it becomes IDR-eligible.
E/M Level & Documentation Review
We verify the billed E/M level is supported by documented complexity and resources, reducing downgrade and denial risk.
Facility & Professional Fee Coordination
Professional and facility billing are tracked as separate, correctly coordinated revenue streams rather than treated as one claim.
Submission & IDR Tracking
Claims are submitted and tracked to resolution, including dedicated status tracking for claims in the federal IDR process.
Denial Management & Appeals
Level-of-service, medical-necessity, and payer-dispute denials are appealed with documentation matched to what reviewers actually require.
Medical Billing Denial Management: How to Cut Your Denial Rate Below 5% in 2025
The CARC codes and prevention system behind fewer denials — including the level-of-service disputes ED claims see often.
Read article Patient SchedulingPatient Scheduling Best Practices That Reduce No-Shows and Fill Gaps
High-volume urgent care scheduling shares a lot with ED throughput — same-day capacity is the whole game.
Read articleMedVersify Emergency Medicine Billing
Billing That Understands the No Surprises Act.
Nationwide billing support for ER physician groups and urgent care organizations.