News & Analysis as of

Out of Network Provider Cost-Sharing

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

Cornerstone Research

5 Questions with Erin Trish: Surprise Billing in Healthcare

Cornerstone Research on

5 Questions is a periodic feature produced by Cornerstone Research, which asks our professionals, senior advisors, or affiliated experts to answer five questions. We interview Professor Erin Trish, of the Schaeffer Center...more

Mintz - Health Care Viewpoints

Mintz IRA Update — Other Key IRA Programs and Developments: The Medicare Prescription Drug Inflation Rebate Program and Maximum...

Although most of the recent focus around the implementation of the Inflation Reduction Act (“IRA”) by the press and industry stakeholders has been on the Medicare Drug Price Negotiation Program, the IRA has several other...more

Rivkin Radler LLP

Transparency in Coverage Final Rule Took Effect on July 1

Rivkin Radler LLP on

The Centers for Medicare & Medicaid Services’ Transparency in Coverage Final Rule took effect on July 1, following a six-month delay in implementation to allow payers to come into compliance....more

Manatt, Phelps & Phillips, LLP

[Webinar] No Surprises Act Implementation: Immediate Challenges for Payers and Providers - March 30th, 1:00 pm - 2:00 pm ET

The federal No Surprises Act (NSA), which went into effect January 1, 2022, protects patients from surprise medical bills for emergency services and for when they are treated by out-of-network providers in an in-network...more

Blank Rome LLP

Surprise! Federal Court Invalidates CMS Arbitration Procedure under No Surprises Act

Blank Rome LLP on

The Eastern District of Texas recently issued its opinion in Texas Medical Association v. United States Department of Health and Human Services, et al., invalidating key portions of regulations implementing the out-of-network...more

McGuireWoods LLP

Court Strikes HHS No Surprises Act’s Independent Dispute Resolution Procedures

McGuireWoods LLP on

On Feb. 23, 2022, the U.S. District Court for the Eastern District of Texas granted a motion for summary judgment in favor of the Texas Medical Association and Dr. Adam Corley, striking down a portion of an interim final rule...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Federal "No Surprises Act" Is Now the Law

On January 1, 2022, the Biden Administration’s Federal No Surprises Act (NSA) took effect. The NSA provides new protections against unsuspected medical bills. It is intended to combat the negative impact of the rising cost of...more

Manatt, Phelps & Phillips, LLP

CFPB Will Enforce Laws Preventing the Collection/Reporting of Medical Debts Barred by the NSA

As part of the Biden administration’s focus on enforcement of the No Surprises Act (NSA), the Consumer Financial Protection Bureau (CFPB) has issued a bulletin (the Bulletin) indicating that it will closely review the...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

K&L Gates LLP

Surprise Billing Regulations: Out-of-Network Providers at In-Network Facilities

K&L Gates LLP on

On 1 July 2021, the Department of the Treasury, the Department of Labor, and the Department of Health and Human Services (the Departments) issued an interim final rule (IFR) implementing certain provisions of the No Surprises...more

Bass, Berry & Sims PLC

First Installment of Surprise Billing Regulations Released

On July 1, the Department of Health and Human Services (HHS), Department of Labor, and Department of the Treasury (Departments) jointly issued interim final rules (IFR) implementing certain aspects of the No Surprises Act...more

Manatt, Phelps & Phillips, LLP

[Webinar] Navigating the No Surprises Act: Your Guide to Requirements, Challenges & Compliance - August 2nd, 1:00 pm - 2:00 pm ET

What New Obligations Does the No Surprises Act Impose on Health Systems and Health Plans—and How Can You Prepare for the Impact? Learn the Answer at a New Manatt Webinar. The No Surprises Act (NSA)—set to take effect...more

Chambliss, Bahner & Stophel, P.C.

HHS and Other Agencies Issue Interim Final Rule on Surprise Billing

Earlier this month, the U.S. Department of Health and Human Services, Department of Labor, Department of the Treasury, and the Office of Personnel Management issued an interim final rule with a comment period on the issues of...more

Groom Law Group, Chartered

Surprise! Tri-Agencies Meet Deadline with First Set of Surprise Billing Rules, With More to Come

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (“DOL”) (collectively, the “Departments”), released the interim final...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Initial No Surprises Act Regulations Provide Some Clarity for Employer Plans

Plan participants can be hit with surprise medical bills when they receive care from out-of-network providers. Sometimes, this happens when participants do not know that the care they are receiving is from an out-of-network...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

Bradley Arant Boult Cummings LLP

No More Surprises? New Rule on Surprise Medical Bills

The U.S. Departments of Health and Human Services, Labor, and Treasury, and the Office of Personnel Management have issued "Requirements Related to Surprise Billing; Part I," an interim final rule to implement the No...more

Husch Blackwell LLP

Federal Guidance On Balance Billing: The No Surprises Act And Its Interim Final Rule: Part I

Husch Blackwell LLP on

On July 1, 2021, the Office of Personnel Management (“OPM”), the Internal Revenue Service (“IRS”), the Department of Treasury (“Treasury”), the Employee Benefits Security Administration (“EBSA”), the Department of Labor...more

Hogan Lovells

No Surprises Act prohibits balance billing, creates arbitration process for out-of-network providers

Hogan Lovells on

Effective January 1, 2022, the “No Surprises Act” signed into U.S. law as part of H.R. 133, “Consolidated Appropriations Act, 2021,” implicates (1) emergency services provided by non-participating providers at participating...more

McAfee & Taft

RADICAL new transparency rules likely to apply to your health plan in one year

McAfee & Taft on

New rules published last month likely require your employer health plan to phase-in certain disclosures over a three-year period beginning in one year: 1. January 1, 2022 (three files must be disclosed): For plan years...more

Seyfarth Shaw LLP

Final Rule regarding Transparency in Coverage for Health Care Services

Seyfarth Shaw LLP on

Seyfarth Comments: The final Transparency in Coverage Rule was published jointly by the Departments of Health and Human Services, Treasury, and Labor on November 12, 2020. The Rule aims to increase transparency in...more

Proskauer - Minding Your Business

A Test Costs What? Pricing and Reimbursing COVID-19 Tests

Out-of-network providers appear to be inflating the price of COVID-19 diagnostic and antibody tests, according to a recent America’s Health Insurance Plans (AHIP) survey. The October 2020 survey reports that out-of-network...more

Bricker Graydon LLP

Surprise COVID-19 medical bills: What providers can and cannot do

Bricker Graydon LLP on

Providers have faced many challenges since the start of the COVID-19 pandemic and have needed to quickly react to changing laws and regulatory requirements impacting their operations. One such change is the restrictions on...more

Bond Schoeneck & King PLLC

Federal Agencies Clarify Coronavirus Testing Coverage Mandate

In an earlier information memo we described the coverage mandate for coronavirus testing and related items and services imposed on health plans under the Families First Coronavirus Response Act (FFCRA). Congress subsequently...more

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