News & Analysis as of

Interim Final Rules (IFR) Out of Network Provider

Manatt, Phelps & Phillips, LLP

Challenges to the Final August 2022 No Surprises Act Independent Dispute Resolution Rule

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

Cozen O'Connor

New Final Rules under the No Surprises Act: Four Takeaways

Cozen O'Connor on

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

Bass, Berry & Sims PLC

No Surprises Act: New Regulations Improve Dispute Resolution Process for Providers

Bass, Berry & Sims PLC on

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

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

How does the Federal No Surprises Act Impact Telemedicine Providers? Part Two

Foley & Lardner LLP on

In this second installment of this blog series on the No Surprises Act interim regulations (NSA) we discuss: i) notice and consent requirements for out of network providers providing services at participating health care...more

Morgan Lewis - ML Benefits

Surprise! Texas District Court Strikes Down Portions of No Surprises Act

In the case of Texas Medical Ass'n, et al. v. US Department of Health and Human Services, et al., the US District Court for the Eastern District of Texas on February 23 invalidated portions of the second interim final rule...more

Troutman Pepper

Providers Prevail in Challenge to No Surprises Act Interim Final Rule

Troutman Pepper on

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

Morgan Lewis - Health Law Scan

Texas Court Strikes Down Part of Federal Surprise Billing Rules

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

Groom Law Group, Chartered

A Surprise Turn of Events for the No Surprises Act Dispute Resolution Process

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

Dentons

Victory for Providers: Court Vacates a Portion of the No Surprises Act’s Informal Dispute Resolution Rule

Dentons on

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

Verrill

Surprise Medical Bills: Texas District Court Vacates Portion of Independent Dispute Resolution (IDR) Process in Agency Rule

Verrill on

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

Epstein Becker & Green

Federal District Court Vacates QPA Rebuttable Presumption Provisions of No Surprises Act Regulations

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

Seyfarth Shaw LLP

No More Surprises, But Much Uncertainty Over Non-Network Bills

Seyfarth Shaw LLP on

Seyfarth Synopsis: Last summer and fall, the Departments of Treasury, Labor, and Health and Human Services issued Interim Final Rules (IFRs) [here] and [here], implementing the sweeping changes that applied to out-of-network...more

Polsinelli

Federal Court Strikes Portions of Regulations Implementing No Surprises Act

Polsinelli on

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

Akerman LLP - Health Law Rx

Surprised Providers Seek Changes to Latest Provisions of the No Surprises Act

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

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

Pullman & Comley - Connecticut Health Law

The Federal No Surprises Act: 10 Things Connecticut Providers Should Know Now

The Federal No Surprises Act (42 USC §300gg-111 et seq.), effective for plan years beginning January 1, 2022, restricts surprise bills for patients with job-based or individual health care coverage who receive...more

Maynard Nexsen

New IDR Rules Under The No Surprises Act

Maynard Nexsen on

On September 30, 2021, the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (collectively, the “Departments”) released an interim final rule with comment period entitled...more

Proskauer - Health Care Law Brief

The Devil may be in the Details of the Part II No Surprises Act IFR

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

Payne & Fears

The Many Unpleasant Surprises in the No Surprises Act Regulations

Payne & Fears on

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

Manatt, Phelps & Phillips, LLP

Second NSA Interim Final Rule Focuses on Independent Dispute Resolution, Good Faith Estimates

The Big Picture - The Biden Administration released an interim final rule with comment period (IFC) on September 30 that answers an important remaining question under the No Surprises Act (NSA): How will the amount that...more

Akerman LLP - Health Law Rx

Providers Get Unpleasant Surprise from Latest Provisions to the No Surprises Act

Efforts to stop surprise medical costs are continuing to evolve. The Departments of Health and Human Services (“HHS”), Labor, and Treasury (collectively, the “Departments”), and the Office of Personnel Management issued an...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

Polsinelli

Health Care Reimbursement and Payor Dispute Update - September 2021

Polsinelli on

On July 1, 2021, the Departments of Health and Human Services (“HHS”), Treasury, and Labor, along with the Office of Personnel Management (collectively the “Departments”), issued the first tranche of regulations implementing...more

Polsinelli

New Federal Surprise Billing Prohibition and Its Implication on State Laws

Polsinelli on

On July 1, 2021, the Biden-Harris Administration issued “Requirements Related to Surprise Billing; Part 1,” an interim final rule (IRM) that will restrict health care providers and facilities from sticking patients with...more

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