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Seyfarth Shaw LLP

Agencies Release Final Mental Health Parity Rule

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On Monday, September 9, 2024, the Departments of Health and Human Services, Labor and Treasury (the “Departments”) issued their final rule regarding the nonquantitative treatment limitation (NQTL) comparative analysis...more

Sheppard Mullin Richter & Hampton LLP

No Surprises Here – Providers Win Again in No Surprises Act TMA III Litigation Vacating Independent Dispute Resolution Rule

On August 2, 2024, the United States Fifth Circuit affirmed the rulings in the No Surprises Act litigation brought by the Texas Medical Association and other plaintiffs challenging the August 2022 Final Rule that has been...more

McDermott Will & Emery

Six Wishes for the Forthcoming Final Regulations Under MHPAEA

McDermott Will & Emery on

On July 1, 2024, the US Department of Labor (DOL) submitted final regulations to the Congressional Budget Office (CBO), implementing the Mental Health Parity and Addiction Equity Act (MHPAEA) as most recently amended by the...more

Cozen O'Connor

CMS Announces 120-day Exception Period for No Surprises Act Independent Dispute Resolution

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Under the No Surprises Act, “open negotiation” is the period of time during which payers must disclose to providers important information regarding the claim at issue. On June 14, 2024, CMS announced a 120-calendar-day...more

Seyfarth Shaw LLP

Agencies Defer Final Action on Junk Insurance, While Suggesting Caution Against One Last “Binge”

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The agencies have finalized a portion of their proposed rules impacting so-called “junk insurance” regarding short-term limited-duration insurance, but deferred finalizing the more significant changes that would have impacted...more

Rivkin Radler LLP

Federal Rules Limit “Junk” Health Plans

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On March 28, the U.S. Departments of Health and Human Services, Labor and the Treasury collectively issued final rules with respect to short-term and limited duration insurance (STLDI) plans in an effort to reduce healthcare...more

McDermott+

New No Surprises Act Announcements Indicate Bumpy Road Ahead

McDermott+ on

The bumpy road toward implementing the No Surprises Act took another turn last Friday, October 6, 2023. The US Departments of Health and Human Services (HHS), Labor and the Treasury (collectively, the Departments) provided...more

McDermott+

McDermottPlus Check-Up: October 6, 2023

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THIS WEEK’S DOSE - Uncharted Territory in the House: The House voted to remove Rep. McCarthy (R-CA) as Speaker of the House, then recessed until at least October 11, when the House is slated to reconvene to elect a new...more

Foley & Lardner LLP

The No Surprises Act: The Departments Proposed Another Increase to IDR Fee, Will it Stick?

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On September 26, 2023, the Departments of Health & Human Services (HHS), Labor, and the Treasury (collectively, the Departments) jointly proposed rules (September Rule) updating the administrative fee and Certified...more

Bass, Berry & Sims PLC

Court Strikes Down Federal Surprise Billing QPA Calculation Rules, Continuing Pause on Arbitrations

Bass, Berry & Sims PLC on

On August 24, the U.S. District Court for the Eastern District of Texas once again struck down parts of the regulations governing the arbitration process created by the No Surprises Act (NSA) to settle payment disputes...more

Seyfarth Shaw LLP

Mental Health Compliance Report Issued to Congress Spoiler Alert – Plans All Fail

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Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Seyfarth Shaw LLP

Mental Health Request for Public Comment Spoiler Alert – The Departments Need Help

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Seyfarth Synopsis: The Mental Health Parity and Addiction Equity Act (MHPAEA) requires group health plans and insurers to cover treatments for mental health and substance use disorders in a manner that is equitable to the...more

Ballard Spahr LLP

Details Upon Details: Compliance Under MHPAEA’s New Proposed Regulations

Ballard Spahr LLP on

Summary - The Departments of Labor, Health and Human Services, and the Treasury have proposed regulations under the Mental Health Parity Act that build on prior guidance to set forth requirements for an extremely detailed...more

Epstein Becker & Green

Independent Dispute Resolution Process Halted Following the Government’s Third Major No Surprises Act-Related Loss in Federal...

Epstein Becker & Green on

On August 3, 2023, the U.S. Department of Health & Human Services (“HHS”), the Department of Labor, and the Department of Treasury (collectively, the “Departments”) temporarily suspended the federal Independent Dispute...more

Ballard Spahr LLP

New Mental Health Parity Guidance Issued

Ballard Spahr LLP on

Summary - On July 25, 2023, the Departments of Labor, Treasury, and Health & Human Services (the Departments) released joint proposed regulations and other guidance under the Paul Wellstone and Pete Domenici Mental Health...more

McDermott Will & Emery

Agencies Issue FAQs on Surprise Billing and Cost-Sharing Rules Coordination

McDermott Will & Emery on

A recent article by the Kaiser Family Foundation (KFF) and National Public Radio (NPR) raised the prospect that patients may still see surprise medical bills despite the enactment of the No Surprises Act (NSA)....more

Ballard Spahr LLP

Meet Me at the Corner of No Surprises and …

Ballard Spahr LLP on

Summary - The Departments of Labor, Health and Human Services, and the Treasury have issued guidance that coordinates application of the No Surprise Billing rules under the Consolidated Appropriations Act, 2021, with the...more

Snell & Wilmer

Five Facts About the Annual Gag Clause Prohibition Compliance Attestation

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Effective December 27, 2020, the Consolidated Appropriations Act, 2021 (“CAA”), as part of its transparency in health care protections, prohibits group health plans and issuers from entering into agreements that directly or...more

Akerman LLP - Health Law Rx

Stop – Go – Stop Again – Now GO… Surprised by the No Surprises Act?

We are not surprised by the continued stop-and-go regarding guidance surrounding the No Surprises Act. Most recently, a Texas court vacated portions of the No Surprises Act’s updated final rule (the final rules were discussed...more

Akerman LLP - Health Law Rx

Finally, More Certainty and Fewer Surprises – Final Rules Issued Under the No Surprises Act

The Departments of the Treasury, Labor, and Health and Human Services (the Departments) issued final rules related to the No Surprises Act on August 26, 2022, to be effective October 25, 2022 (Final Rules).  These Final Rules...more

Robinson+Cole Health Law Diagnosis

New Final Rule Under the No Surprises Act Released

On August 19, 2022, the Department of Health and Human Services (HHS), Department of Labor (DOL), and Department of the Treasury (DOT), released “Requirements Related to Surprise Billing: Final Rules” (the Rules). The Rules...more

Moore & Van Allen PLLC

Health Care Client Update: No Surprises Act

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On January 1, 2022, two Interim Final Rules (the “Rules”) that implement key aspects of the No Surprises Act (“NSA”) became effective. The first Interim Final Rule was initially issued by the U.S. Departments of Health and...more

Roetzel & Andress

President Biden’s Executive Orders: Impact On Employee Benefits And Healthcare

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In the opening days of his administration, President Biden has signed a flurry of Executive Orders impacting multiple sectors of the U.S. economy. This article summarizes the Orders that impact employee benefits and...more

Verrill

Consolidated Appropriations Act of 2021 Includes Flexible Spending Account Relief

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The Consolidated Appropriations Act of 2021 (the “Act”) was signed into law on December 27, 2020. Buried within its 5,593 pages is some welcome flexibility relating to 2020 and 2021 health care and dependent care Flexible...more

Burr & Forman

What the HRA is going on with HRAs?

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On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

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