News & Analysis as of

Department of Health and Human Services (HHS) Consolidated Appropriations Act (CAA) Surprise Medical Bills

Ballard Spahr LLP

Courts Split on Enforcement of No Surprises Rules

Ballard Spahr LLP on

The Fifth Circuit and the Federal District Court of Connecticut have issued conflicting decisions on whether service providers may sue to enforce arbitration awards under the No Surprises Rules in the Consolidated...more

McDermott+

No Surprises Act Implementation Under the Trump Administration

McDermott+ on

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

Snell & Wilmer

2024 End-of-Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

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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 SW Benefits Updates. This Part 1 covers year-end health and welfare plan issues. Parts 2,...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 & Schulte

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

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 & Schulte

NSA Update: HHS Indefinitely Delays Co-Provider, Co-Facility Requirements for Good Faith Estimates

McDermott Will & Schulte 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

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

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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

McDermott Will & Schulte

Telemedicine Providers Take Note – The No Surprises Act Is Effective January 1, 2022

McDermott Will & Schulte 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

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

Seyfarth Shaw LLP

If You Have Been Racing to Meet these Deadlines… You May Have Just Gotten an Extension

Seyfarth Shaw LLP on

Seyfarth Synopsis: The Departments of Labor, Health and Human Services, and Treasury (the “Departments”) have issued FAQs which address certain provisions of the Affordable Care Act (ACA) and Title I (No Surprises Act) and...more

McAfee & Taft

New health plan guidance regarding transparency regulations and last year’s budget act

McAfee & Taft on

Late last Friday afternoon, the Departments of Labor, Health and Human Services, and the Treasury issued some new frequently asked questions (FAQs) regarding implementation of the transparency in coverage (TIC) regulations...more

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

New Guidance Delays Some Key CAA and Other Health Benefit Effective Dates

New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly - but only slightly - more manageable heading into 2022....more

Faegre Drinker Biddle & Reath LLP

Part One of Surprise Medical Billing Regulatory Guidance Outlines Specific Required Changes to Group Health Plan Payment...

The No Surprises Act (the “NSA”), which was signed into law at the end of 2020 as part of the Consolidated Appropriations Act, is designed to protect consumers from unexpected medical bills. The NSA generally applies to...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

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

Holland & Knight LLP

HHS Issues Interim Final Rule Implementing Certain Provisions of the No Surprises Act

Holland & Knight LLP on

The U.S. Departments of Health and Human Services (HHS), Labor and Treasury, along with the Office of Personnel Management, on July 1, 2021, issued a much-anticipated Interim Final Rule with Comment Period (IFC) –...more

Husch Blackwell LLP

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

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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

Bass, Berry & Sims PLC

The No Surprises Act Passed and (Surprise!) Healthcare Providers are Leery of its Impact

After a drawn-out drafting-and-review process, the hotly contested No Surprises Act (Act) has made its way into law after being tucked into the 5,500+ pages of the Consolidated Appropriations Act, 2021, signed into law on...more

Holland & Hart LLP

Consolidated Appropriations Act, 2021 (CAA) Benefits Summary

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The COVID-Related Tax Relief Act of 2020, the Taxpayer Certainty and Disaster Tax Relief Act of 2020, and the No Surprises Act, all part of the Consolidated Appropriations Act, 2021 (CAA, 2021), which was signed into law on...more

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