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Out of Network Provider Health Care Providers Department of Health and Human Services (HHS)

Proskauer - Health Care Law Brief

No Surprises Here!  Fifth Circuit Upholds Health Care Provider Challenge to No Surprises Act Regulations

In a recent win for health care providers, the United States Court of Appeals for the Fifth Circuit has affirmed a lower court’s decision to vacate key portions of regulations issued by the U.S. Departments of Treasury,...more

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

DOL, HHS, and Treasury Release FAQs about No Surprises Act after TMA III

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The U.S. Departments of Labor (DOL), Health and Human Services (HHS), and Treasury, along with the Office of Personnel Management (OPM), released FAQs about the implementation of Title I of Division BB of the Consolidated...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

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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

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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

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

Sheppard Mullin Richter & Hampton LLP

No Surprises Act Update: Federal IDR Temporarily Suspended After Court Vacates Increased Administrative Fees and Rule for Batching...

On August 3, 2023, the United States District Court for the Eastern District of Texas once again ruled in favor of the Texas Medical Association[1] and vacated portions of the guidance related to (i) the administrative fee...more

Manatt, Phelps & Phillips, LLP

NSA Update: IDR Process Suspended After TX District Court Invalidates Batching and Fee Increases

Last week, after several slow news months for the No Surprises Act (NSA), a Texas district court issued its most recent decision in a series of cases brought by the Texas Medical Association and other health care providers...more

Kramer Levin Naftalis & Frankel LLP

No Surprises Here: Providers Score Third Victory in No Surprises Act Litigation, Other Challenges to the NSA Continue

Congress enacted the No Surprises Act (NSA) in 2020 to reduce surprise medical bills and to provide a simple and fast procedure for out-of-network health care providers to obtain payment from insurers. The U.S. Department of...more

McDermott Will & Emery

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

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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

King & Spalding

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

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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

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

Court Once Again Strikes Down Payer-Friendly Provisions in Surprise Billing Regulations

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On February 6, the U.S. District Court for the Eastern District of Texas vacated key provisions in the regulations implementing a federal arbitration process to settle out-of-network (OON) payment disputes between payers and...more

Epstein Becker & Green

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

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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

Saul Ewing LLP

The 2022 Evolution of the No Surprises Act

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The No Surprises Act (“NSA”) is a federal law that went into effect January 1, 2022. The NSA statute was enacted as part of the Consolidated Appropriations Act, 2021 and has been implemented by three interim rules jointly...more

Mintz - Employment Viewpoints

HHS, Treasury and Labor Issue More Guidance on the No Surprises Act

Title I of Division BB of the Consolidated Appropriations Act, 2021 (the “Act”), and interim final rules issued by the Departments of Health and Human Services, Treasury and Labor (the “Departments”) in July 2021 (see our...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

Butler Snow LLP

The No Surprises Act – Anticipating Unanticipated Consequences

Butler Snow LLP on

The “law of unintended consequences” describes the general sociological principle that for every action there is an unintended or unanticipated outcome. An influential examination of the concept was published in 1936 by...more

Cozen O'Connor

New Final Rules under the No Surprises Act: Four Takeaways

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On August 19, 2022, the United States Departments of Health and Human Services, Labor and Treasury released final rules (“Final Rules”) revising certain provisions of their previously issued interim final rules regarding the...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

Bass, Berry & Sims PLC

No Surprises Act: New Regulations Improve Dispute Resolution Process for Providers

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On August 19, the federal government issued a final rule addressing certain aspects of the No Surprises Act (NSA). The NSA was enacted in December 2020 to protect commercially insured patients from receiving surprise medical...more

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