News & Analysis as of

No Surprises Act (NSA) Healthcare Reform Out of Network Provider

Harris Beach PLLC

Court Rejects IDR Rules in No Surprises Act Case

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Out-of-network health providers recently won a huge legal victory when the Fifth Circuit Court ruled that federal guidelines regarding Independent Dispute Resolution (“IDR”) proceedings were unlawfully slanted in favor of...more

Hall Benefits Law

The No Surprises Act: A Cost Saving Opportunity for Employer Plan Sponsors

Hall Benefits Law on

Benefits costs continue to increase globally, and in the midst of high inflation and potentially a recession, executives are exploring cost effective methods to manage their self-insured health plans without compromising the...more

Ballard Spahr LLP

No Surprises, But Much Uncertainty: The Status of CAA Billing Rules

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Summary - The rules in the Consolidated Appropriations Act that aim to eliminate much of the surprise from billings by out-of-network providers in particular situations are the subject of continued controversy....more

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

Akerman LLP - Health Law Rx

THE NO SURPRISES ACT: Hoping for an End to the Surprises

By looking at the events that have transpired since the Consolidated Appropriations Act, 2021, which includes the No Surprises Act (the Act), was signed into law, it is clear that the Departments of Health and Human Services,...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

Epstein Becker & Green

Texas Federal Court Issues Fourth Ruling Invalidating Parts of the Administration’s No Surprises Act Regulations

Epstein Becker & Green on

On August 24, 2023, the U.S. District Court for the Eastern District of Texas issued an opinion and order in Texas Medical Association, et al. v. United States Department of Health and Human Services(“HHS”)(“TMA III”). TMA...more

Akerman LLP - Health Law Rx

Surprise… No Surprises Act Arbitration Is Too Expensive

Providers finally obtained court ordered relief to the $350 administrative fee each party was required to pay as part of the Federal Independent Dispute Resolution (IDR) Process under the No Surprises Act. Until the...more

Epstein Becker & Green

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

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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

King & Spalding

First Annual Report on the No Surprises Act’s Impact on the Health Care Market is Released

King & Spalding on

On July 6, 2023, the HHS Office of the Assistant Secretary for Planning and Evaluation (ASPE) released the first of five required annual reports on the impact of the No Surprises Act (NSA) on health care markets (the Report)....more

Davis Wright Tremaine LLP

No Surprises Act: Washington State Rethinks IDR Transition Amid Federal Court Showdown

Washington State's Office of the Insurance Commissioner (OIC) is delaying its transition to the federal No Surprises Act (NSA) Independent Dispute Resolution (IDR) process for at least six months. As a result of this...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

Bass, Berry & Sims PLC

Healthcare Regulatory – No Surprises/Surprise Medical Billing

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On February 6, the U.S. District Court for the Eastern District of Texas struck down key regulations implementing the federal arbitration process created under the No Surprises Act (NSA) to settle out-of-network payment...more

Epstein Becker & Green

No Surprises Act: HHS Extends Enforcement Moratorium on Co-Provider & Co-Facility Good Faith Estimates

Epstein Becker & Green on

To the relief of many providers and facilities and with just three weeks to go until the implementation date, the U.S. Department of Health & Humans Services (HHS) announced that it is extending its policy of not enforcing...more

Morgan Lewis - Health Law Scan

More Legal Pressure on HHS to Modify No Surprises Act IDR Rule

Pressure continues to mount on the US Department of Health and Human Services (HHS) to reconsider and revise its August 2022 final rule modifying the No Surprises Act independent dispute resolution (IDR) process. The rule is...more

Manatt, Phelps & Phillips, LLP

Challenges to the Final August 2022 No Surprises Act Independent Dispute Resolution Rule

Controversy continues to surround the independent dispute resolution (IDR) provisions of the No Surprises Act (NSA). On November 18, bipartisan leadership of the House Ways and Means Committee sent a letter to the Secretaries...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

Dentons

No Surprises Act Frequently Asked Questions: Volume 9

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In 2020, Congress passed the No Surprises Act (NSA) in an attempt to protect uninsured patients from surprise billing. Some sections of the NSA became effective on January 1, 2022, while other sections are on hold until...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

Akerman LLP - Health Law Rx

“The No Surprises Act” a/k/a “The Act that Continues Surprising Providers”

The No Surprises Act (the “Act”) continues muddling through its implementation period. We have discussed the Act in prior posts, and most recently on March 8, 2022. The surprises have continued, with new updates coming out...more

Payne & Fears

The Many Unpleasant Surprises in the No Surprises Act Regulations

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The Federal No Surprises Act (“Act”), which goes into effect on January 1, 2022, contains provisions designed to protect insured patients from unexpected hospital and physician bills when they receive emergency services in an...more

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