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Out of Network Provider Dispute Resolution Healthcare Reform

McDermott+

No Surprises Act Implementation Under the Trump Administration

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The No Surprises Act, a law that ended the practice of “balance billing” by certain out-of-network providers, was enacted as part of the Consolidated Appropriations Act of 2021 on December 27, 2020. While the law passed...more

Foley & Lardner LLP

The No Surprises Act: The Departments Proposed Another Increase to IDR Fee, Will it Stick?

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On September 26, 2023, the Departments of Health & Human Services (HHS), Labor, and the Treasury (collectively, the Departments) jointly proposed rules (September Rule) updating the administrative fee and Certified...more

Akerman LLP - Health Law Rx

THE NO SURPRISES ACT: Hoping for an End to the Surprises

By looking at the events that have transpired since the Consolidated Appropriations Act, 2021, which includes the No Surprises Act (the Act), was signed into law, it is clear that the Departments of Health and Human Services,...more

Epstein Becker & Green

Texas Federal Court Issues Fourth Ruling Invalidating Parts of the Administration’s No Surprises Act Regulations

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On August 24, 2023, the U.S. District Court for the Eastern District of Texas issued an opinion and order in Texas Medical Association, et al. v. United States Department of Health and Human Services(“HHS”)(“TMA III”). TMA...more

Akerman LLP - Health Law Rx

Surprise… No Surprises Act Arbitration Is Too Expensive

Providers finally obtained court ordered relief to the $350 administrative fee each party was required to pay as part of the Federal Independent Dispute Resolution (IDR) Process under the No Surprises Act. Until the...more

Epstein Becker & Green

Independent Dispute Resolution Process Halted Following the Government’s Third Major No Surprises Act-Related Loss in Federal...

Epstein Becker & Green on

On August 3, 2023, the U.S. Department of Health & Human Services (“HHS”), the Department of Labor, and the Department of Treasury (collectively, the “Departments”) temporarily suspended the federal Independent Dispute...more

King & Spalding

First Annual Report on the No Surprises Act’s Impact on the Health Care Market is Released

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On July 6, 2023, the HHS Office of the Assistant Secretary for Planning and Evaluation (ASPE) released the first of five required annual reports on the impact of the No Surprises Act (NSA) on health care markets (the Report)....more

Davis Wright Tremaine LLP

No Surprises Act: Washington State Rethinks IDR Transition Amid Federal Court Showdown

Washington State's Office of the Insurance Commissioner (OIC) is delaying its transition to the federal No Surprises Act (NSA) Independent Dispute Resolution (IDR) process for at least six months. As a result of this...more

Akerman LLP - Health Law Rx

Stop – Go – Stop Again – Now GO… Surprised by the No Surprises Act?

We are not surprised by the continued stop-and-go regarding guidance surrounding the No Surprises Act. Most recently, a Texas court vacated portions of the No Surprises Act’s updated final rule (the final rules were discussed...more

Morgan Lewis - Health Law Scan

More Legal Pressure on HHS to Modify No Surprises Act IDR Rule

Pressure continues to mount on the US Department of Health and Human Services (HHS) to reconsider and revise its August 2022 final rule modifying the No Surprises Act independent dispute resolution (IDR) process. The rule is...more

Akerman LLP - Health Law Rx

Finally, More Certainty and Fewer Surprises – Final Rules Issued Under the No Surprises Act

The Departments of the Treasury, Labor, and Health and Human Services (the Departments) issued final rules related to the No Surprises Act on August 26, 2022, to be effective October 25, 2022 (Final Rules).  These Final Rules...more

Dentons

No Surprises Act Frequently Asked Questions: Volume 9

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In 2020, Congress passed the No Surprises Act (NSA) in an attempt to protect uninsured patients from surprise billing. Some sections of the NSA became effective on January 1, 2022, while other sections are on hold until...more

Robinson+Cole Health Law Diagnosis

New Final Rule Under the No Surprises Act Released

On August 19, 2022, the Department of Health and Human Services (HHS), Department of Labor (DOL), and Department of the Treasury (DOT), released “Requirements Related to Surprise Billing: Final Rules” (the Rules). The Rules...more

Polsinelli

Federal Agencies Release a Final Rule Implementing the No Surprises Act’s Independent Dispute Resolution Process

Polsinelli on

On August 19, 2022, three federal agencies tasked with adopting regulations for the No Surprises Act (“NSA”) issued a highly anticipated Final Rule implementing key aspects of the NSA’s independent dispute resolution (“IDR”)...more

Akerman LLP - Health Law Rx

More Turbulence for the No Surprises Act Thanks to Air Ambulance Providers

Given the trajectory, it is no longer surprising that the No Surprises Act (the Act) continues its turbulent path through implementation. The U.S. District Court for the Eastern District of Texas, on July 26, 2022, again...more

Polsinelli

Federal Court Strikes Additional Portions of Regulations Implementing No Surprises Act Addressing Air Ambulance Services

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Five months ago, in TMA v. HHS, et al. (“TMA”), a federal court in Texas struck down portions of a controversial interim final rule (“Rule”) jointly issued by three federal executive agencies (“Departments”) intended to...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

Dentons

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

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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

Jones Day

No Surprises Act Update: Rule Governing Dispute Resolution Process Set Aside

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In a win for health care providers across the nation, the U.S. District Court for the Eastern District of Texas has vacated a key regulation regarding the process for resolving payment disputes between insurers and...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

Morgan Lewis - Health Law Scan

No Surprises Act Requires Good-Faith Estimates and Balance Billing Protections

As its name suggests, the No Surprises Act establishes patient protection against most surprise medical bills from out-of-network, emergency service, and air ambulance providers. Two of the major provisions affecting...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

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

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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

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