News & Analysis as of

Consolidated Appropriations Act (CAA) No Surprises Act (NSA)

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

Ballard Spahr LLP

Fifth Circuit Affirms Invalidity of No Surprises Regulations

Ballard Spahr LLP on

The Fifth Circuit Court of Appeals has affirmed the invalidity of regulations governing the independent review process under the No Surprise Billing Rules....more

Hall Benefits Law

DOL, HHS, and Treasury Release FAQs about No Surprises Act after TMA III

Hall Benefits Law on

The U.S. Departments of Labor (DOL), Health and Human Services (HHS), and Treasury, along with the Office of Personnel Management (OPM), released FAQs about the implementation of Title I of Division BB of the Consolidated...more

Mandelbaum Barrett PC

The No Surprises Act: A Look at What Dentists Need to Know

Mandelbaum Barrett PC on

The Federal No Surprises Act (“NSA”) was signed into law on December 27, 2020, as part of the Consolidated Appropriations Act of 2021. Since its enactment, the NSA has been supplemented on two occasions by regulations which...more

Hogan Lovells

Public comment period reopened for Proposed Rule on No Surprises Act’s IDR Operations

Hogan Lovells on

The Office of Personnel Management (OPM) along with the Departments of Health and Human Services, Labor, and the Treasury (“the Departments”) announced on January 17, 2024, that they have reopened the public comment period...more

McDermott+

Regulatory Reflections from the Past Year

McDermott+ on

As 2023 comes to a close, I can’t help but reflect on all the regulations and policies we reviewed this year (and those that we’ll continue to handle next week before the year actually ends). There were some tasty eggs with...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

Proskauer - Employee Benefits & Executive...

Now Live: Tri-Agencies Release Guidance for Group Health Plan “No Gag Clause” Attestations

On February 23, 2023, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) issued new guidance (in the form of FAQs) implementing the No Surprises Act’s prohibition on “gag clauses” in...more

Foley & Lardner LLP

Key Takeaways from the Foley/PYA “Let’s Talk Compliance” 2-Day Virtual Conference

Foley & Lardner LLP on

Session #1: State of the Healthcare Industry Effective Compliance Plans and Enforcement Trends - In their discussion of compliance program effectiveness and enforcement, attorneys Kolarik and Waltz and Ms. Sumner...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

McDermott Will & Emery

NSA Update: HHS Indefinitely Delays Co-Provider, Co-Facility Requirements for Good Faith Estimates

McDermott Will & Emery on

On December 2, 2022, the US Department of Health and Human Services (HHS) issued an FAQ announcing that it will not enforce the requirement for convening providers and convening facilities to include expected charges for...more

Husch Blackwell LLP

Surprise Billing Final Regulations Issued

Husch Blackwell LLP on

The federal government recently issued final regulations revising certain aspects of the interim final regulations they had previously released implementing the surprise billing rules set forth under the No Surprises Act....more

Foley & Lardner LLP

Price Transparency and CAA Checklist for Plan Service Providers

Foley & Lardner LLP on

Group health plans must comply with several new requirements set forth by the Consolidated Appropriations Act of 2021 (CAA) and the Transparency in Coverage regulations (TiC Regulations) under the Affordable Care Act (ACA). ...more

Snell & Wilmer

2022 End of Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

Snell & Wilmer on

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

Mintz - Employment Viewpoints

HHS, Treasury and Labor Issue More Guidance on the No Surprises Act

Title I of Division BB of the Consolidated Appropriations Act, 2021 (the “Act”), and interim final rules issued by the Departments of Health and Human Services, Treasury and Labor (the “Departments”) in July 2021 (see our...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

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

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