News & Analysis as of

Department of Health and Human Services (HHS) Good Faith

Foley & Lardner LLP

RxDC Reporting Relief for Plans, Issuers, and Plan Service Providers

Foley & Lardner LLP on

On December 23, 2022, the Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) provided welcome relief in the form of an FAQ regarding the Prescription Drug Data Collection (RxDC)...more

Verrill

A Last-Minute Gift – Prescription Drug Reporting Grace Period and Good Faith Relief

Verrill on

In a move akin to last-minute gift-giving, the Departments of Labor, Health and Human Services, and the Treasury (the “Departments”) released FAQ 56 on December 23, 2022, which provides relief regarding the Prescription Drug...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

McDermott Will & Emery

HHS Goes Back to the Drawing Board on the 340B ADR Process

McDermott Will & Emery on

Citing “policy and operational challenges” with the current 340B Administrative Dispute Resolution (ADR) Process, the US Department of Health and Human Services (HHS) has issued a new Proposed Rule to modify the current ADR...more

Foley & Lardner LLP

CMS Extends Delayed Enforcement of the Good Faith Estimate

Foley & Lardner LLP on

On Friday, December 2, 2022, the Centers for Medicare & Medicaid Services (CMS) issued an FAQ regarding the Good Faith Estimate (GFE) and Convening Provider/Facility requirements in the Federal No Surprises Act. The issued...more

Bass, Berry & Sims PLC

No Surprises Act Update: HHS Extends Enforcement Discretion for Co-Provider Good Faith Estimates

Bass, Berry & Sims PLC on

On December 2, the Department of Health and Human Services (HHS) announced it would not begin enforcement of a key requirement under the No Surprises Act (NSA) starting January 1, 2023, as previously scheduled...more

Stevens & Lee

2022 Guidance on No Surprises Act Compliance

Stevens & Lee on

The No Surprises Act (NSA) went into effect Jan. 1, 2022, but since the effective date, there have been numerous updates and changes regarding the NSA and compliance with it. We examine the key NSA 2022 changes and details of...more

King & Spalding

Departments Issue Final No Surprises Act Dispute Resolution Rule and Other Guidance

King & Spalding on

On August 19, 2022, the Departments of Health and Human Services, Labor, and the Treasury (the Departments) issued a long-awaited final rule (the Final Rule) on the Independent Dispute Resolution (IDR) Process under the No...more

Fox Rothschild LLP

Surprise: Long Term Care Providers Are Not Exempt from The No Surprises Act’s Good Faith Estimate Requirement for Uninsured and...

Fox Rothschild LLP on

The federal No Surprises Act and interim final rules implementing the Act went into effect on January 1, 2022. Part I is aimed at reducing “surprise bills” to patients in the context of services provided at hospitals and...more

Moore & Van Allen PLLC

Health Care Client Update: No Surprises Act

Moore & Van Allen PLLC on

On January 1, 2022, two Interim Final Rules (the “Rules”) that implement key aspects of the No Surprises Act (“NSA”) became effective. The first Interim Final Rule was initially issued by the U.S. Departments of Health and...more

McGlinchey Stafford

Employer Primer on COVID-19 Vaccination Policies

McGlinchey Stafford on

The Supreme Court is currently considering the validity of two rules promulgated by federal agencies in the past months regarding vaccines and testing in the workplace. Whether those rules—OSHA’s Emergency Temporary Standard...more

Holland & Hart - Health Law Blog

No Surprise Billing Rules: Good Faith Estimates and Unscheduled Services

The No Surprise Billing Rules took effect January 1, 2022, but many questions remain, including if and to what extent the new rules for good faith estimates apply to items or services that are provided to self-pay patients on...more

ArentFox Schiff

Health Care Providers Take Note: New Surprise Billing Regulations Mandate Provision of “Good Faith Estimates” Uninsured and...

ArentFox Schiff on

Beginning January 1, 2022, all state licensed or certified health care facilities and providers must follow extensive rules for providing a "good faith estimate" of health care charges to uninsured and self-pay patients prior...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

Holland & Hart - Health Law Blog

No Surprise Billing Rules: Checklist for Providers

Many providers make the No Surprise Billing Rules more complicated and expansive than they are. This short guide is intended to help providers understand, implement, and monitor compliance with the new rules. UNDERSTANDING...more

Holland & Knight LLP

CMS Issues Documents to Assist Providers with No Surprises Act Compliance

Holland & Knight LLP on

The Centers for Medicare & Medicaid Services (CMS) recently released template documents and model notices to help healthcare providers comply with the No Surprises Act, which was passed as part of the Consolidated...more

ArentFox Schiff

No More Surprise Medical Bills: Second ‘No Surprises Act’ Rule Issued, But More Remains to Be Done

ArentFox Schiff on

The Departments of Health and Human Services, Labor, and Treasury, and the Office of Personnel Management issued this Fall their second long-awaited interim final rule implementing the federal No Surprises Act (the “Act”),...more

Foley & Lardner LLP

Government Issues No Surprises Act Interim Final Rule with Comment Period (Part II)

Foley & Lardner LLP on

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

King & Spalding

Biden Administration Issues Additional No Surprises Act Guidance in New Interim Final Rules

King & Spalding on

On September 30, 2021, the Biden Administration issued the second set of implementing regulations under the No Surprises Act. The interim final rules, issued by the Departments of Health and Human Services, Labor, and...more

Cozen O'Connor

Five Things Providers Need To Know About The New Interim Final Rule Under The “No Surprises” Act

Cozen O'Connor on

On Thursday, September 30, 2021, The United States departments of Health and Human Services (“HHS”), Labor and Treasury released an interim final rule (“Rule”) that completes most of the regulatory framework under the federal...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

Fox Rothschild LLP

Proposed Amendment To NC’s CON Law Would Raise Cost Thresholds, Require Expirations

Fox Rothschild LLP on

North Carolina legislators filed another bill to amend the state’s Certificate of Need Act on April 1, 2021. As filed, Senate Bill 462 would modify several longstanding cost thresholds that trigger CON review:.. ...more

Snell & Wilmer

The Arizona Supreme Court Joins Other States in Ruling that HIPAA Can Be Used to Establish the Standard of Care in a Negligent...

Snell & Wilmer on

On March 8, 2021, the Arizona Supreme Court held in Shepherd v. Costco1 that the plaintiff, Greg Shepherd, was permitted to bring a negligence claim for wrongful disclosure of medical information and that the Health Insurance...more

ArentFox Schiff

Proposed HIPAA Regulations Would Improve Individual Patient Care and Expand Patient Rights

ArentFox Schiff on

Nearly two years after soliciting public suggestions to modify HIPAA rules to improve the coordination of care, the Department of Health and Human Services (DHHS) issued a Proposed Rule which changes parts of the Privacy Rule...more

Bass, Berry & Sims PLC

What Healthcare Providers Need to Know About the Information Blocking Rules

Bass, Berry & Sims PLC on

On March 9, 2020, the U.S. Department of Health and Human Services (HHS) published final rules to implement the information blocking prohibitions of the 21st Century Cures Act (Information Blocking Rules). The Information...more

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