On July 13, 2021, the Biden administration (“Administration”) officially published the “Requirements Related to Surprise Billing; Part I”—its first regulatory response to the enactment of the No Surprises Act (“NSA”)—as an interim final rule with a request for comments (“First NSA Rule”) in the Federal Register. Issued by the U.S. Office of Personal Management and the Departments of Health and Human Services, Labor, and the Treasury, the First NSA Rule leads the series of regulations the Administration expects to issue to implement the NSA, which goes into effect on January 1, 2022. The Administration initially released the First NSA Rule to the public as a pre-issuance on July 1, 2021, to meet the first regulatory deadline imposed by the NSA...