News & Analysis as of

Out of Network Provider Out-of-Pocket Expenses

Ballard Spahr LLP

Surprise, Surprise! No Surprise Billing Regulations Upheld

Ballard Spahr LLP on

The Fifth Circuit Court of Appeals recently upheld regulations defining the qualifying payment amount (QPA). The QPA is a key factor in determining how much individuals and health plans must pay out-of-network providers in...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

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

Bass, Berry & Sims PLC

Court Strikes Down Federal Surprise Billing QPA Calculation Rules, Continuing Pause on Arbitrations

Bass, Berry & Sims PLC on

On August 24, the U.S. District Court for the Eastern District of Texas once again struck down parts of the regulations governing the arbitration process created by the No Surprises Act (NSA) to settle payment disputes...more

Epstein Becker & Green

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

Epstein Becker & Green on

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

Snell & Wilmer

CMS' Transparency-in-Coverage Rule: One Year Later

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In October 2020, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Transparency in Coverage Rule (“the Rule”), requiring most health insurance plans and issuers offering individual or group coverage to...more

King & Spalding

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

King & Spalding on

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

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

No Surprises Act Guidance on Out-of-Pocket Maximums and Facility Fees

Employers have some new clarity on the No Surprises Act rules on out-of-network providers and charges under new guidance from the U.S. Department of Labor, U.S. Department of the Treasury, and the U.S. Department of Health...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

Bass, Berry & Sims PLC

Healthcare Regulatory – No Surprises/Surprise Medical Billing

Bass, Berry & Sims PLC on

On February 6, the U.S. District Court for the Eastern District of Texas struck down key regulations implementing the federal arbitration process created under the No Surprises Act (NSA) to settle out-of-network payment...more

Epstein Becker & Green

No Surprises Act: HHS Extends Enforcement Moratorium on Co-Provider & Co-Facility Good Faith Estimates

Epstein Becker & Green on

To the relief of many providers and facilities and with just three weeks to go until the implementation date, the U.S. Department of Health & Humans Services (HHS) announced that it is extending its policy of not enforcing...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

Dentons on

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

Dentons

No Surprises Act Frequently Asked Questions: Volume 8

Dentons on

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

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

Dentons

No Surprises Act Frequently Asked Questions: Volume 7

Dentons on

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

Dentons

No Surprises Act Frequently Asked Questions: Volume 6

Dentons on

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

Dentons

No Surprises Act Frequently Asked Questions: Volume 5

Dentons on

Congress passed the No Surprises Act to protect patients from surprise billing from health care providers. Some parts of the Act became effective on January 1, 2022. Health care lawyer Susan Freed is answering frequently...more

Polsinelli

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

Polsinelli on

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

Dentons

No Surprises Act Frequently Asked Questions: Volume 4

Dentons on

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

Dentons

No Surprises Act Frequently Asked Questions: Volume 3

Dentons on

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

Dentons

No Surprises Act: Frequently Asked Questions - Volume 2

Dentons on

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

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