Air-Ambulance Out-of-Network Claims Were Cut in Half After 2021—Then Rebounded in Year Two

A large decline, followed by a reversal

GAO’s commercial-claims sample recorded 3,773 out-of-network air-ambulance claims among 38,280 in 2019–2021, or 9.86%. In 2022–2023 it recorded 1,554 among 31,145, or 4.99%—a 4.87-point, 49.4% decline.

The annual record is less reassuring. The rate fell from 10.2% in 2021 to 3.8% in 2022, then rose to 6.1% in 2023. The out-of-network count grew from 596 to 958, a 60.7% increase, while total sampled claims stayed nearly flat.

The law changed the bill, not necessarily the network

The No Surprises Act protects many insured patients from out-of-network balance bills for emergency air transport and routes payment disputes between plans and providers into a federal process. A claim may remain out of network even when the patient is protected from the difference.

GAO found the lower post-2021 rate but could not attribute the change to the law alone. Market exits, contracting choices and the study database’s coverage can also affect the series.

A broad database with a narrow denominator

The underlying Komodo dataset covers about 110 million patients, but GAO’s air-ambulance analysis used roughly 69,000 qualifying claims across the five years. The sample is useful for comparison but is not designed to produce a census of every U.S. transport or insurer.

What’s the Scoop With Broach pooled the pre- and post-law counts and recomputed the decline and rebound. The original contribution is the two-stage view: a sustained improvement relative to 2019–2021 alongside a substantial second-year backslide.

What the finding does not show

The data do not show how many patients received an improper bill, what insurers ultimately paid, or whether the 2023 increase continued. The record supports a monitoring question, not a claim that the statutory protections failed.