On July 1, 2021, the Departments of Health and Human Services (“HHS”), Treasury, and Labor, along with the Office of Personnel Management (collectively the “Departments”), issued the first tranche of regulations implementing the No Surprises Act (“NSA”) titled “Requirements Related to Surprise Billing; Part I” (the “Part I IFR”), and requested stakeholder comments on a handful of issues in the Part I IFR. This article describes some of the Part I IFR’s key takeaways.
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