News & Analysis as of

Surprise Medical Bills Department of Labor (DOL) Health Care Providers

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

Cozen O'Connor

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

Cozen O'Connor on

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

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

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

ArentFox Schiff

No More Surprise Medical Bills: In Another Victory for Providers, Texas Court Vacates Administrative Fee and Batching Provisions...

ArentFox Schiff on

On August 3, 2023, health care providers in Texas scored yet another victory when a federal court vacated additional portions of the Biden Administration’s rules governing fee collection and claim batching under the federal...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

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

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

Manatt, Phelps & Phillips, LLP

New Guidance Instructs IDR Entities to Move Forward With Some Payment Disputes While Holding Others

The Department of Health and Human Services, the Department of Labor and the Department of the Treasury (the Departments) are continuing to respond to decisions by a federal district court in Texas regarding the Independent...more

Bass, Berry & Sims PLC

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

Bass, Berry & Sims PLC on

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

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

Clark Hill PLC

US Departments of Labor, Health and Human Services, and Treasury Issue Final Rules To Clarify Federal Process To Protect Against...

Clark Hill PLC on

Final Rules Make Medical Claim Payment Process More Transparent - Final rules issued earlier this month and effective for the Jan. 1, 2022, plan year (the current year for most employer-provided welfare plans) provide details...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

Bass, Berry & Sims PLC on

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

Foley & Lardner LLP

Behavioral Health Trends for 2022

Foley & Lardner LLP on

Over the last two years, behavioral health (BH) has been one of the biggest growth areas in the health care ecosystem, fueled by the Public Health Emergency (PHE) but in many ways an ignored, overlooked, understaffed, and...more

Verrill

Surprise Medical Bills: Texas District Court Vacates Portion of Independent Dispute Resolution (IDR) Process in Agency Rule

Verrill on

The U.S. District Court for the Eastern District of Texas recently vacated a portion of the Requirements Related to Surprise Billing, Part II, Interim Final Rule (the “Rule”) regarding the independent dispute resolution (IDR)...more

Moore & Van Allen PLLC

Health Care Client Update: No Surprises Act

Moore & Van Allen PLLC on

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

McDermott Will & Emery

Telemedicine Providers Take Note – The No Surprises Act Is Effective January 1, 2022

McDermott Will & Emery on

On December 27, 2020, the No Surprises Act was signed into law as part of the Consolidated Appropriations Act, 2021. In July and October 2021, respectively, the Department of Health and Human Services, the Department of...more

ArentFox Schiff

No More Surprise Medical Bills: Second ‘No Surprises Act’ Rule Issued, But More Remains to Be Done

ArentFox Schiff on

The Departments of Health and Human Services, Labor, and Treasury, and the Office of Personnel Management issued this Fall their second long-awaited interim final rule implementing the federal No Surprises Act (the “Act”),...more

Maynard Nexsen

New IDR Rules Under The No Surprises Act

Maynard Nexsen on

On September 30, 2021, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) released an interim final rule with comment period entitled...more

Goodwin

HHS, Labor, and Treasury Departments Defer Enforcement of Transparency in Coverage and No Surprises Act Requirements

Goodwin on

The No Surprises Act and Transparency in Coverage final rules go into effect January 1, 2022. Implemented as Titles I and II of Division BB of the Consolidated Appropriations Act, these rules are intended to protect patients...more

Snell & Wilmer

Not All Surprises Are Good – Phase I of the Surprise Billing Rules

Snell & Wilmer on

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (collectively the “Departments”) issued the interim final rule...more

Bass, Berry & Sims PLC

First Installment of Surprise Billing Regulations Released

On July 1, the Department of Health and Human Services (HHS), Department of Labor, and Department of the Treasury (Departments) jointly issued interim final rules (IFR) implementing certain aspects of the No Surprises Act...more

Groom Law Group, Chartered

Surprise! Tri-Agencies Meet Deadline with First Set of Surprise Billing Rules, With More to Come

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (“DOL”) (collectively, the “Departments”), released the interim final...more

Bradley Arant Boult Cummings LLP

Federal Agencies Release Interim Final Rule to Implement the No Surprises Act

Today, the Departments of Health and Human Services (HHS), Labor, and Treasury (the Departments) published an interim final rule (the Interim Final Rule) implementing certain provisions of the No Surprises Act,[1] which aims...more

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