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Disclosure Requirements Price Transparency

Robinson+Cole Health Law Diagnosis

CMS Issues Guidance and Requests Information to Promote Hospital Price Transparency Compliance and Enforcement Efforts

On May 22, 2025, the Centers for Medicare & Medicaid Services (CMS) took a series of actions to promote enhanced price transparency compliance by hospitals and identify challenges thereto, in order to inform future price...more

Troutman Pepper Locke

Price Transparency: Massachusetts Adopts New Consumer Protection Rules

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The Massachusetts attorney general’s (AG) office has finalized new consumer protection regulations aimed at eliminating hidden “junk fees” and improving price transparency. Set to take effect on September 2, the regulations...more

Foster Garvey PC

Hospital Price Transparency: What Hospitals Need to Know About Trump's Executive Order

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On February 28, 2025, President Trump issued Executive Order 14221 (“EO”), which requires the Federal government to “promote universal access to clear and accurate health care prices” and “increase enforcement of price...more

Kelley Drye & Warren LLP

“Junk Fee” Legislative Roundup – 2025 Edition

2024 was an action-packed year for followers of federal and state laws and regulations governing the disclosure of fees, or so-called ​“junk fee” laws....more

Vedder Price

Trump Administration Issues Executive Order Mandating Implementation and Enforcement of Health Care Pricing Transparency

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On February 25, 2025, President Donald J. Trump signed an executive order titled “Making America Healthy Again by Empowering Patients with Clear, Accurate, and Actionable Healthcare Pricing Information” (the “2025 Order”)...more

Dorsey & Whitney LLP

New Junk Fees Rules to Take Effect in 2025

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The new year will bring significant changes to Minnesota’s retail landscape. Effective January 1, 2025, the Minnesota Deceptive Trade Practices Act (“MDTPA”) will contain new price transparency provisions requiring that...more

Alston & Bird

FTC Issues Final Rule on Junk Fees for Live Ticketing and Short-Term Lodging

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Our Consumer Protection/FTC Team breaks down the Federal Trade Commission’s final rule regulating live-event ticket and hotel pricing practices....more

Arnall Golden Gregory LLP

Minnesota Jumps on the Pricing Transparency Bandwagon

Minnesota is the latest state to join the roster of those that have recently adopted pricing transparency laws. As background, on February 11, 2024, New York amended General Business Law 518 to provide that consumers could...more

Kilpatrick

5 Key Takeaways - Marketing and Advertising in California: Compliance with the "Honest Pricing Law"

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Kilpatrick partners Michele Floyd and Evan Nadel recently presented a webinar to the Association of Corporate Counsel’s Georgia Chapter on the topic of “Marketing and Advertising in California: Compliance with the 'Honest...more

Shook, Hardy & Bacon L.L.P.

The Price is Wrong: Amendment to the California Consumers Legal Remedies Act Requires New Price Disclosures

On July 1, 2024, the “junk fee” amendment to the California Consumers Legal Remedies Act (CLRA) will go into effect. Under this new provision, it will be a violation of the CLRA if a company advertises, displays, or offers...more

Fisher Phillips

New ERISA Class Actions Zero in on Group Health Plan Fiduciary Obligations: 10 Best Practices for Employers

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ERISA class action lawsuits against retirement plan fiduciaries have become commonplace over the last few decades, usually alleging that imprudent processes and lack of oversight led to excessive fees for investment options,...more

Jenner & Block

New California Law Targets Drip Pricing

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A new California law, Senate Bill No. 478, takes aim at “drip pricing,” the practice of advertising goods or services at one price and then adding mandatory charges or fees later in the sales transaction. While federal...more

Alston & Bird

FTC Finalizes CARS Rule Imposing Substantial Regulatory Requirements on Auto Dealerships

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The Federal Trade Commission (FTC) has finalized its Combating Auto Retail Scams Trade Regulation (CARS) Rule, which will affect almost every aspect of auto advertising and sales. Our Consumer Protection/FTC Team explains how...more

McDermott Will & Emery

Proposed Legislation Would Require Greater Transparency and Disclosure from Hospitals, Reduce Reimbursement to Certain Off-Campus...

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Two bills are moving in the United States House of Representatives that have implications for hospitals and health systems, with material changes proposed regarding pricing transparency requirements, identification and...more

White & Case LLP

2022 Drug Pricing Update: States Continue Legislative Push Even As Congress Passes Long Sought Changes

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States remain at the forefront of legislative efforts on a range of issues relating to drug pricing, such as increasing price transparency, capping out-of-pocket costs for insulin, and limiting certain PBM practices. These...more

Bass, Berry & Sims PLC

Enforcement of the Transparency in Coverage Public Disclosure Requirement Rapidly Approaching

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Starting July 1, 2022, employers that maintain group health plans (plans) and health insurance issuers (issuers) will be required to disclose pricing information on a public website in the form of three machine-readable files...more

Faegre Drinker Biddle & Reath LLP

Deadline Approaches for Employers to Post Machine-Readable Files on a Public Website

The July 1st deadline is quickly approaching for non-grandfathered group health plans and issuers to publicly disclose, in accordance with the Transparency in Coverage Final Rules, price information in machine-readable files...more

Foley & Lardner LLP

Employer Checklist for New Health Plan Price Transparency Rules and CAA

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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

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

Rivkin Radler LLP

Hospitals Violate Price Transparency Rule; CMS Proposes Increased Penalties

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A new federal hospital price transparency rule that took effect on January 1, 2021, requires hospitals to post all prices for services online in an easily accessible format. However, a report recently released by...more

Foley & Lardner LLP

Hospital Price Transparency: CMS Issues Proposed Rule to Increase Penalties for Larger Hospitals Violating Disclosure Requirements

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On July 19, 2021 the Centers for Medicare and Medicaid Services (CMS), as part of proposed rule covering a variety of subjects, including Medicare Hospital Outpatient and Ambulatory Surgery Center PPS modifications, issued a...more

Bradley Arant Boult Cummings LLP

Federal Agencies Release Interim Final Rule to Implement the No Surprises Act

Today, the Departments of Health and Human Services (HHS), Labor, and Treasury (the Departments) published an interim final rule (the Interim Final Rule) implementing certain provisions of the No Surprises Act,[1] which aims...more

ArentFox Schiff

North Dakota Becomes Latest State to Enact Drug Transparency Law

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Similar to the laws of several other states, the North Dakota law contains three main disclosure requirements that apply to “drug manufacturers” - The Governor of North Dakota signed House Bill 1032 into law on April 27,...more

Burr & Forman

Hospital Price Transparency Rule – January 1, 2021 Effective Date

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As if hospitals don’t have enough challenges to deal with in caring for patients with COVID-19 and diverting resources to manage the COVID-19 public health emergency, they also need to make sure they comply with the new...more

Bricker Graydon LLP

The uncertain future of the price transparency rule in 2021

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The Trump administration’s hospital price transparency rule went into effect on January 1, 2021, after it was upheld by the U.S. Court of Appeals for the District of Columbia Circuit in a December 2020 decision....more

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