News & Analysis as of

Surprise Medical Bills Consolidated Appropriations Act (CAA)

Ballard Spahr LLP

Fifth Circuit Affirms Invalidity of No Surprises Regulations

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The Fifth Circuit Court of Appeals has affirmed the invalidity of regulations governing the independent review process under the No Surprise Billing Rules....more

Mandelbaum Barrett PC

The No Surprises Act: A Look at What Dentists Need to Know

Mandelbaum Barrett PC on

The Federal No Surprises Act (“NSA”) was signed into law on December 27, 2020, as part of the Consolidated Appropriations Act of 2021. Since its enactment, the NSA has been supplemented on two occasions by regulations which...more

Hogan Lovells

Public comment period reopened for Proposed Rule on No Surprises Act’s IDR Operations

Hogan Lovells on

The Office of Personnel Management (OPM) along with the Departments of Health and Human Services, Labor, and the Treasury (“the Departments”) announced on January 17, 2024, that they have reopened the public comment period...more

Ballard Spahr LLP

No Surprises, But Much Uncertainty: The Status of CAA Billing Rules

Ballard Spahr LLP on

Summary - The rules in the Consolidated Appropriations Act that aim to eliminate much of the surprise from billings by out-of-network providers in particular situations are the subject of continued controversy....more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

McDermott Will & Emery

No Surprises Act and Three Takeaways on Surprise Billing from the Initial Report on the Independent Dispute Resolution (IDR)...

McDermott Will & Emery on

Enacted as Division BB of the Consolidated Appropriations Act, 2021, the No Surprises Act (NSA) provides federal protections against surprise billing with respect to: - Emergency services (including post-stabilization...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

Husch Blackwell LLP

Surprise Billing Final Regulations Issued

Husch Blackwell LLP on

The federal government recently issued final regulations revising certain aspects of the interim final regulations they had previously released implementing the surprise billing rules set forth under the No Surprises Act....more

Ballard Spahr LLP

Dispute Resolution Process Is Modified Under the CAA's No Surprise Billing Rules

Ballard Spahr LLP on

Summary - The Departments of Labor, Treasury, and Health & Human Services have finalized regulations regarding the dispute resolution process implemented under the No Surprise Billing Rules in the Consolidated...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

Deadline Approaching Under Health Plan Price Transparency Rules – Public Disclosure of Provider Reimbursement Rates Due by July 1,...

Foley & Lardner LLP on

Enforcement of one of the Transparency in Coverage Final Rules (“TiC Rules”) begins on July 1, 2022. The rule requires plans and issuers to make machine-readable files publicly available that will disclose in-network rates...more

Foley & Lardner LLP

Behavioral Health Trends for 2022

Foley & Lardner LLP on

Over the last two years, behavioral health (BH) has been one of the biggest growth areas in the health care ecosystem, fueled by the Public Health Emergency (PHE) but in many ways an ignored, overlooked, understaffed, and...more

Mintz - Employment Viewpoints

Health Plan Transparency and the Case for Welfare Plan Fiduciary Committees

The Consolidated Appropriations Act, 2021 (the “Act”) adopted a series of transparency requirements that apply to employer-sponsored group health plans. These transparency rules impose a series of new and complex obligations...more

Jackson Lewis P.C.

Court Strikes Down a Portion of the No Surprises Act Interim Regulations

Jackson Lewis P.C. on

While health plans, insurers, and providers are busy understanding and implementing the new requirements under the No Surprises Act, a U.S. District Court recently vacated an essential portion of the interim regulations...more

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

No Surprises Act: Federal Court Invalidates Parts of the Independent Dispute Resolution Process

On February 23, 2022, the U.S. District Court for the Eastern District of Texas struck down the part of the interagency interim final rule implementing the “independent dispute resolution” (IDR) procedures created by the No...more

Manatt, Phelps & Phillips, LLP

CMS Publishes Letters on No Surprises Act Enforcement in States

The federal Centers for Medicare & Medicaid Services (CMS) has begun publishing on its website letters that it sent to states beginning in December 2021 that provide important information regarding the manner in which the...more

Laner Muchin, Ltd.

New Employer Group Health Plan Compliance Obligations for 2022

Laner Muchin, Ltd. on

With each new year, new legal obligations for employers sponsoring group health plans seem to arrive. This article provides a brief overview and reminder of some of the new key requirements for 2022, many of which we have...more

Perkins Coie

Ringing in the New Year: Key Developments for Health Plan Sponsors

Perkins Coie on

There are many new and expanding legal requirements for group health plans and issuers of group health plan coverage to pay attention to this year. Many of these requirements were enacted as part of the Consolidated...more

Ballard Spahr LLP

Understanding the New 'No Surprises Rules'

Ballard Spahr LLP on

Summary - The following is the first publication in our series on the Consolidated Appropriations Act 2021 (CAA) and transparency regulations. It concerns the rules designed to prevent surprise billings. These No Surprises...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

Jackson Lewis P.C.

AMA and AHA Seek to Enjoin Certain Provisions of the No Surprises Act’s Implementing Rule

Jackson Lewis P.C. on

In December 2020, Congress passed the “No Surprises Act” (NSA) as part of the Consolidated Appropriations Act of 2021. The NSA applies most commonly in situations where a patient receives out-of-network medical services from...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

Foley & Lardner LLP

Employer Checklist for New Health Plan Price Transparency Rules and CAA

Foley & Lardner LLP on

The effective date is fast approaching for certain provisions of the Consolidated Appropriations Act of 2021 (“CAA”) and related regulations, and the Transparency in Coverage Rule. You can access previous articles written...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

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

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