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

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

Deadline Approaching Under Health Plan Price Transparency Rules – Public Disclosure of Provider Reimbursement Rates Due by July 1,...

Enforcement of one of the Transparency in Coverage Final Rules (“TiC Rules”) begins on July 1, 2022. The rule requires plans and issuers to make machine-readable files publicly available that will disclose in-network rates...more

Behavioral Health Trends for 2022

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

Employer Checklist for New Health Plan Price Transparency Rules and CAA

The effective date is fast approaching for certain provisions of the Consolidated Appropriations Act of 2021 (“CAA”) and related regulations, and the Transparency in Coverage Rule. You can access previous articles written...more

Government Issues No Surprises Act Interim Final Rule with Comment Period (Part II)

On September 30, 2021, the U.S. Departments of Health and Human Services (HHS), Labor and Treasury (collectively, the Departments) along with the Office of Management and Budget released “Requirements Related to Surprise...more

Federal Government Publishes an Interim Final Rule (Part 1) Implementing the No Surprises Act

Over the last several years, both the federal government and a number of state legislatures have sought to find a solution to the billing by out-of-network providers, referred to as “Out of Network Billing” (OON Billing) and...more

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