News & Analysis as of

Billing Consolidated Appropriations Act (CAA)

McDermott+

No Surprises Act Implementation Under the Trump Administration

McDermott+ on

The No Surprises Act, a law that ended the practice of “balance billing” by certain out-of-network providers, was enacted as part of the Consolidated Appropriations Act of 2021 on December 27, 2020. While the law passed...more

Foley & Lardner LLP

CMS Expands Access to Behavioral Health Services; Physician Fee Schedule Expands Billing Providers and Flexibilities

Foley & Lardner LLP on

On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) issued its 2024 Physician Fee Schedule final rule (Final Rule) for calendar year 2024 that will, in part, implement some of the most important changes...more

Ballard Spahr LLP

No Surprises, But Much Uncertainty: The Status of CAA Billing Rules

Ballard Spahr LLP on

Summary - The rules in the Consolidated Appropriations Act that aim to eliminate much of the surprise from billings by out-of-network providers in particular situations are the subject of continued controversy....more

McDermott Will & Emery

No Surprises Act and Three Takeaways on Surprise Billing from the Initial Report on the Independent Dispute Resolution (IDR)...

McDermott Will & Emery on

Enacted as Division BB of the Consolidated Appropriations Act, 2021, the No Surprises Act (NSA) provides federal protections against surprise billing with respect to: - Emergency services (including post-stabilization...more

Jackson Lewis P.C.

New No Surprises Act Guidance -Frequently Asked Questions Bolster Final Rule

Jackson Lewis P.C. on

The No Surprises Act (Act), which establishes protections for health plan participants from surprise medical billing, was passed in late 2020 as part of the 2021 Consolidated Appropriations Act....more

Foley & Lardner LLP

Health Plans’ Prior Authorization Rules are under Scrutiny by the DOL for Mental Health Parity Compliance – See the DOL’s Top Five...

Foley & Lardner LLP on

On January 25, 2022, the U.S. Departments of Labor (“DOL”), Treasury, and Health and Human Services (the “Departments”) provided a report (the “Report”) on Mental Health Parity and Addiction Equity Act (“MHPAEA”) compliance...more

Roetzel & Andress

Don't Let the 'No Surprises Act' Catch You by Surprise

Roetzel & Andress on

As of January 1, 2022, certain provisions of the “Consolidated Appropriations Act,” commonly referred to as the “No Surprises Act” (Act), are in effect. The Act amends the Public Health Service Act, Employee Retirement Income...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

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

Holland & Hart - The Benefits Dial

Baby, What a Big Surprise! Right Before My Very Eyes…

The No Surprises Act (part of the Consolidated Appropriations Act introduced earlier this year) is poised to eliminate some of the surprises that group health plan participants encounter from unexpected charges. One way the...more

Hogan Lovells

No Surprises Act prohibits balance billing, creates arbitration process for out-of-network providers

Hogan Lovells on

Effective January 1, 2022, the “No Surprises Act” signed into U.S. law as part of H.R. 133, “Consolidated Appropriations Act, 2021,” implicates (1) emergency services provided by non-participating providers at participating...more

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