News & Analysis as of

Out of Network Provider Patient Protection and Affordable Care Act (PPACA)

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Snell & Wilmer

Enforcement Back On: Departments Rescind Enforcement Relief for Machine Readable File Requirements under Transparency in Coverage...

Snell & Wilmer on

On September 27th, the Departments released FAQs about Affordable Care Act Implementation Part 61 (“FAQ 61”), announcing that the Departments are rescinding prior-issued enforcement relief for certain machine-readable file...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

Foley & Lardner LLP

Several New Group Health Plan Reporting Deadlines Are Approaching – Check Out Our CAA/Price Transparency Checklist

Foley & Lardner LLP on

This year, Foley’s Health Benefits Practice has released multiple alerts on several of the new group health plan requirements set forth by the Consolidated Appropriations Act of 2021 (CAA) and the Transparency in Coverage...more

FordHarrison

Transparency in Coverage Requirements – Compliance Deadline Approaching

FordHarrison on

Summary: For Health Plans, Machine-Readable Files, containing in-network provider charges and out-of-network allowed amounts and billed charges, must be posted on a public website by July 1, 2022....more

Jackson Lewis P.C.

Transparency in Coverage Enforcement

Jackson Lewis P.C. on

On April 19, 2022, the Departments of Labor, Health and Human Services, and the Treasury issued additional guidance under the Transparency in Coverage Final Rules issued in 2020. The guidance, FAQs About Affordable Care Act...more

Fisher Phillips

Departments Delay Enforcement of Transparency Disclosure Requirements

Fisher Phillips on

Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more

Rivkin Radler LLP

Federal Government Delays Enforcement Of Price Transparency Rule

Rivkin Radler LLP on

The federal government will delay for six months its enforcement of key portions of the Transparency in Coverage (TiC) final rule that goes into effect on January 1, 2022. The change was announced in guidance issued jointly...more

Sheppard Mullin Richter & Hampton LLP

Federal Government Announces Enforcement Discretion, Deferral For Certain Price Disclosures And Future Rulemakings

Health plans and issuers racing to implement overlapping price transparency and disclosure requirements in response to the Transparency in Coverage final rule (TiC Final Rule) and the Consolidated Appropriations Act, 2021...more

K&L Gates LLP

Surprise Billing Regulations: Impact on Out-of-Network Providers

K&L Gates LLP on

On 1 July 2021, the United Stated Office of Personnel Management, and the Departments of the Treasury, Labor, and Health and Human Services (collectively, the Departments) issued an Interim Final Rule (the IFR) implementing...more

Morgan Lewis

Biden-Harris Administration Issues Part I of Surprise Billing Rule

Morgan Lewis on

The US Departments of Treasury, Labor, and Health and Human Services (the Departments) along with the Office of Personnel Management (OPM) issued Requirements Related to Surprise Billing; Part I on July 1. ...more

Holland & Knight LLP

HHS Issues Interim Final Rule Implementing Certain Provisions of the No Surprises Act

Holland & Knight LLP on

The U.S. Departments of Health and Human Services (HHS), Labor and Treasury, along with the Office of Personnel Management, on July 1, 2021, issued a much-anticipated Interim Final Rule with Comment Period (IFC) –...more

Husch Blackwell LLP

Federal Guidance On Balance Billing: The No Surprises Act And Its Interim Final Rule: Part I

Husch Blackwell LLP on

On July 1, 2021, the Office of Personnel Management (“OPM”), the Internal Revenue Service (“IRS”), the Department of Treasury (“Treasury”), the Employee Benefits Security Administration (“EBSA”), the Department of Labor...more

Manatt, Phelps & Phillips, LLP

Accessing Out-of-Network Subspecialty Cancer Care in Marketplace Plans

In a new report prepared in partnership with the Leukemia & Lymphoma Society (LLS), summarized below, Manatt Health reviews policy challenges that may hamper patients’ ability to navigate and obtain proper treatment for their...more

Patrick Malone & Associates P.C. | DC Injury...

Better Healthcare Newsletter from Patrick Malone - March 2021

IN THIS ISSUE - As patients struggle with unreal prices, health reformers zero in on hospitals - Smart ways to negotiate a bill down - With public outcry rising on health costs, governments and employers are...more

McAfee & Taft

Employer health plans must pay the cost of a COVID-19 vaccine

McAfee & Taft on

As many have likely heard, multiple COVID-19 vaccine candidates have rapidly reached the final stages of development and are showing extraordinary effectiveness. The vaccines are beginning to be submitted to the FDA for...more

Manatt, Phelps & Phillips, LLP

[Webinar] COVID-19: The Road Ahead for Commercial Health Insurance - April 23rd, 2:00 pm - 3:00 pm ET

Examine the Evolving Challenges That Lie Ahead for Healthcare Stakeholders and State Regulators—and What You Can Do Now to Prepare and Protect Your Organization—at a New Manatt Webinar. Effective health insurance...more

Patrick Malone & Associates P.C. | DC Injury...

Congress and White House find a bipartisan target in medical bills and prices

Doctors, hospitals, health insurers, and Big Pharma have become so abusive to patients with their billing and pricing that they may have accomplished what many consider a political impossibility ?  angering Democrats and...more

Manatt, Phelps & Phillips, LLP

Departments Survive Legal Challenge, Clarify “Greatest-of-Three” Regulation

On May 1, 2018, the U.S. Departments of Labor, Health & Human Services and the Treasury (Departments) clarified the Patient Protection and Affordable Care Act’s (ACA) “greatest-of-three” regulation (GOT regulation) in...more

Holland & Knight LLP

Connecticut District Court Provides Interpretation of ACA Provision - Decision Allows Insurers to Circumvent Hospitals in...

Holland & Knight LLP on

• The ACA does not prevent insurers from declining to directly reimburse out-of-network hospitals for emergency care, and instead adjudicate and administer claims directly with individual patients, the U.S. District Court for...more

Foley & Lardner LLP

Will the Massachusetts Proposed Legislation on Hospital Outpatient Facility Fees Have a Nationwide Impact?

Foley & Lardner LLP on

In some states, including the Commonwealth of Massachusetts, “site neutrality” for outpatient hospital reimbursement is factoring into state-specific health reform and cost containment initiatives. This potentially goes...more

King & Spalding

Court Instructs Federal Agencies to Re-Examine Their Response to Comments Regarding Out-of-Network Emergency Services...

King & Spalding on

On August 31, 2017, the U.S. District Court for the District of Columbia held that HHS, the Department of Labor and the Department of Treasury (the Departments) failed to adequately address commenters’ concerns and proposed...more

Manatt, Phelps & Phillips, LLP

Manatt on Health Reform: Weekly Highlights - September 2016

The national uninsurance rate hits a record low; Georgia’s Chamber of Commerce outlines three Medicaid expansion proposals; and California legislation targets surprise medical bills. FEDERAL AND STATE MARKETPLACE NEWS: ...more

Winstead PC

Waves of Guidance and Benefit Plan Developments Worth Watching

Winstead PC on

Notices on Second Round of Privacy and Security Audits are Out, Expat Plans, OON Surgery Center Billing Issues, and New Nondiscrimination Rules for Federal Contractors, New ERISA Civil Monetary Penalties, COBRA Notices and...more

BCLP

New ACA, et. al. FAQs Cover Items From “Top” to “Bottom”

BCLP on

On April 20, the “Big Three” agencies (DOL, Treasury/IRS, and HHS) released another set of FAQs (the 31st, for those of you counting at home). Consistent with earlier FAQs, the new FAQs cover a broad range of items under the...more

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