We previously noted that the regulations implementing the No Surprises Act (“NSA”) appeared to be inconsistent with the NSA because they seemed to establish the qualifying payment amount (“QPA”) as the appropriate payment...more
8/31/2022
/ Billing ,
Department of Health and Human Services (HHS) ,
Department of Labor (DOL) ,
Dispute Resolution ,
Health Care Providers ,
Health Insurance ,
Healthcare Facilities ,
Hospitals ,
Interim Final Rules (IFR) ,
No Surprises Act (NSA) ,
U.S. Treasury
We previously noted that the No Surprises Act (NSA) regulation’s establishment of the presumption that the qualifying payment amount (QPA)—generally, the median payment by the plan to providers in the region—is the...more
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
In a FAQ published on August 20, 2021, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) significantly delayed implementation of statutory requirements on surprise billing...more
9/3/2021
/ Affordable Care Act ,
Consolidated Appropriations Act (CAA) ,
Delays ,
Health Care Providers ,
Health Insurance ,
Healthcare Reform ,
Hospitals ,
Price Transparency ,
Public Disclosure ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process ,
Statutory Requirements ,
Surprise Medical Bills
This post provides an update to our previous publication summarizing the federal No Surprises Act and is part two of two in a series on new interim regulations implementing certain requirements of the No Surprises Act.
In...more
This post provides an update to our previous publication summarizing the federal No Surprises Act and is part one of two in a series on new interim regulations implementing certain requirements of the No Surprises Act....more
As promised, this is a follow-up to our first blog post on the new federal transparency requirements. In our prior post, we summarized the Hospital Price Transparency rule which went into effect on January 1, 2021, and here...more
Yesterday, the Supreme Court heard oral argument in King v. Burwell, which some describe as an argument over a mere four words – "established by the state." But to the surprise of many, the Justices did not spend most of the...more