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Podcast: No Surprises Act: New Rules and Guidance for Stakeholders (Part 1) - Diagnosing Health Care
On November 28, 2023, the Departments of Health and Human Services, Labor, and the Treasury (the Departments) issued two sets of FAQs on aspects of the No Surprises Act (NSA) Independent Dispute Resolution Process (IDR...more
Controversy continues to surround the independent dispute resolution (IDR) provisions of the No Surprises Act (NSA). On November 18, bipartisan leadership of the House Ways and Means Committee sent a letter to the Secretaries...more
On August 19, 2022, the United States Departments of Health and Human Services, Labor and Treasury released final rules (“Final Rules”) revising certain provisions of their previously issued interim final rules regarding the...more
We previously noted that the regulations implementing the No Surprises Act (“NSA”) appeared to be inconsistent with the NSA because they seemed to establish the qualifying payment amount (“QPA”) as the appropriate payment...more
On August 19, the federal government issued a final rule addressing certain aspects of the No Surprises Act (NSA). The NSA was enacted in December 2020 to protect commercially insured patients from receiving surprise medical...more
The Centers for Medicare & Medicaid Services and other agencies together issued final regulations concerning the independent dispute resolution process for settling provider-payor disputes over reimbursement for...more
On February 23, 2022, the Federal Eastern District of Texas vacated the interim final rule regulations that establish the independent dispute resolution provisions of the No Surprises Act (NSA). On April 22, the Department of...more
On February 23, 2022, the United States District Court for the Eastern District of Texas invalidated portions of Part II of the interim final rule (“IFR”) issued by the U.S. Departments of Health and Human Services, Labor,...more
On February 23, a Texas federal court vacated several key portions of an interim final rule (Rule) governing the No Surprises Act's (Act) independent dispute resolution (IDR) process. The court's decision has been lauded by...more
A federal judge in Texas held on February 23 that the federal government’s interim final rule implementing the independent dispute resolution (IDR) process established by the No Surprises Act conflicted with the plain...more
The ongoing implementation of the No Surprises Act’s (“NSA”) prohibition on surprise balance billing, and the related independent dispute resolution (“IDR”) process between payers and providers became much less certain after...more
On February 23, 2022, the U.S. District Court for the Eastern District of Texas struck down the part of the interagency interim final rule implementing the “independent dispute resolution” (IDR) procedures created by the No...more
Several provisions of the No Surprises Act took effect on January 1, 2022, including prohibitions on out of network providers balance billing patients for emergency services provided by out of network providers and facilities...more
The U.S. District Court for the Eastern District of Texas recently vacated a portion of the Requirements Related to Surprise Billing, Part II, Interim Final Rule (the “Rule”) regarding the independent dispute resolution (IDR)...more
On February 23, 2022, in the case captioned Texas Med. Ass’n v. U.S. Dep’t of Health & Human Servs., No. 6:21-cv-00425-JDK (E.D. Tex.), the U.S. District Court for the Eastern District of Texas issued the first major judicial...more
On Wednesday, February 23, 2022, a federal court in Texas struck down five controversial portions of the interim final rule (“Rule”) jointly issued by three federal executive agencies (“Departments”) that implement the...more
Effective January 1, 2022, new billing protections went into effect that have the goal of providing greater protections for patients against surprise medical bills. As we discussed in our prior blog, the Departments of Health...more
Editor’s Note: In this article, Manatt Health provides an update on the latest policy developments around the No Surprises Act (NSA) and the vaccination mandate for health care workers....more
The No Surprises Act (NSA) will go into effect on January 1, 2022. Since our last episode on the topic, the federal government has issued additional interim final rules and guidance to implement the NSA, including the second...more
On November 5, 2021, 152 members of the U.S. House of Representatives submitted a letter to the Secretaries of the Departments of Health and Human Services, Labor, and the Treasury (the Departments) urging the Departments to...more
This post reviews Part II of the federal No Surprises Act regulations. In previous publications, we have commented upon the No Surprises Act, and Part I of the regulations. The “Requirements Related to Surprise Billing;...more
The Federal No Surprises Act (“Act”), which goes into effect on January 1, 2022, contains provisions designed to protect insured patients from unexpected hospital and physician bills when they receive emergency services in an...more
This alert summarizes recent rules implementing the federal independent dispute resolution (IDR) process under the No Surprises Act (the Act). In a nutshell, the federal IDR process is the process in which arbitrators decide...more
The U.S. Departments of Health and Human Services (HHS), Labor (DOL), Treasury and Office of Personnel Management on Sept. 30, 2021, jointly released a second interim final rule (IFR) with comment period implementing...more
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