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Department of Labor (DOL) U.S. Treasury Health Care Providers

King & Spalding

Second Circuit Affirms Lower Court’s Ruling Rejecting Neurological Surgery Provider’s Challenge to the No Surprises Act

King & Spalding on

On July 22, 2025, the United States Court of Appeals for the Second Circuit affirmed the judgment of the United States District Court for the Eastern District of New York, which dismissed an amended complaint brought by...more

Holland & Knight LLP

Holland & Knight Health Dose: September 10, 2024

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Holland & Knight Health Dose is an in-depth weekly dose of legislative and regulatory insights to keep stakeholders abreast of happenings in Washington, D.C., impacting the health sector....more

Proskauer - Health Care Law Brief

No Surprises Here!  Fifth Circuit Upholds Health Care Provider Challenge to No Surprises Act Regulations

In a recent win for health care providers, the United States Court of Appeals for the Fifth Circuit has affirmed a lower court’s decision to vacate key portions of regulations issued by the U.S. Departments of Treasury,...more

ArentFox Schiff

No More Surprise Medical Bills: Fifth Circuit Affirms Vacatur of Arbitration Provisions of Surprise Billing Rules (TMA II)

ArentFox Schiff on

On August 2, health care providers scored yet another significant victory when the US Court of Appeals for the Fifth Circuit affirmed the vacatur of various federal regulations regarding the arbitration procedures used to...more

Sheppard Mullin Richter & Hampton LLP

No Surprises Here – Providers Win Again in No Surprises Act TMA III Litigation Vacating Independent Dispute Resolution Rule

On August 2, 2024, the United States Fifth Circuit affirmed the rulings in the No Surprises Act litigation brought by the Texas Medical Association and other plaintiffs challenging the August 2022 Final Rule that has been...more

Cozen O'Connor

CMS Announces 120-day Exception Period for No Surprises Act Independent Dispute Resolution

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Under the No Surprises Act, “open negotiation” is the period of time during which payers must disclose to providers important information regarding the claim at issue. On June 14, 2024, CMS announced a 120-calendar-day...more

ArentFox Schiff

No More Surprise Medical Bills: Biden Administration Finalizes Rule Resetting Administrative Fees for No Surprises Act...

ArentFox Schiff on

On December 18, 2023, the US Departments of Treasury, Labor, and Health and Human Services (the Departments) issued a rule finalizing the 2024 non-refundable administrative fee parties must pay to access the arbitration...more

McDermott+

New No Surprises Act Announcements Indicate Bumpy Road Ahead

McDermott+ on

The bumpy road toward implementing the No Surprises Act took another turn last Friday, October 6, 2023. The US Departments of Health and Human Services (HHS), Labor and the Treasury (collectively, the Departments) provided...more

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

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

ArentFox Schiff

No More Surprise Medical Bills: In Another Victory for Providers, Texas Court Vacates Administrative Fee and Batching Provisions...

ArentFox Schiff on

On August 3, 2023, health care providers in Texas scored yet another victory when a federal court vacated additional portions of the Biden Administration’s rules governing fee collection and claim batching under the federal...more

Foley & Lardner LLP

The No Surprises Act: A District Court’s Decision Results in Federal IDR Outage

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Although the No Surprises Act was signed into law almost three years ago and has been in effect for the past year and a half, there have been numerous delays in implementation and execution due to the complexity of elements...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

McDermott Will & Schulte

Agencies Issue FAQs on Surprise Billing and Cost-Sharing Rules Coordination

A recent article by the Kaiser Family Foundation (KFF) and National Public Radio (NPR) raised the prospect that patients may still see surprise medical bills despite the enactment of the No Surprises Act (NSA)....more

Foley & Lardner LLP

High Deductible Health Plan First Dollar Coverages in Flux

Foley & Lardner LLP on

A recent string of lawsuits, regulatory guidance, and market trends have dramatically impacted the types of services that enjoy first dollar coverage under high deductible health plan (HDHP) and health savings account (HSA)...more

Ballard Spahr LLP

Gag-Clause Attestations Due by End of Year

Ballard Spahr LLP on

Summary - By December 31, 2023, health plans and insurers must submit an attestation of compliance with the anti-gag rules of the Consolidated Appropriations Act, 2021 (CAA). The rules apply to all agreements entered into...more

McDermott Will & Schulte

Departments Release Update on No Surprises Act Independent Dispute Resolution Process

On April 27, 2023, The Departments of Health and Human Services (HHS), Labor, and the Treasury (the Departments) released a status update on the Federal Independent Dispute Resolution (IDR) Process, which covers the period...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

ArentFox Schiff

No More Surprise Medical Bills: Providers Continue to Pursue Additional Challenges to Government Rulemaking Under No Surprises Act

ArentFox Schiff on

In parallel cases, health care providers are continuing to challenge rulemaking by the US Departments of Treasury, Labor, and Health and Human Services (the Departments) under the No Surprises Act (the Act). Having already...more

Bass, Berry & Sims PLC

Court Once Again Strikes Down Payer-Friendly Provisions in Surprise Billing Regulations

Bass, Berry & Sims PLC on

On February 6, the U.S. District Court for the Eastern District of Texas vacated key provisions in the regulations implementing a federal arbitration process to settle out-of-network (OON) payment disputes between payers and...more

King & Spalding

Texas Medical Association Files Third Challenge to No Surprises Act

King & Spalding on

On November 30, 2022, the Texas Medical Association (TMA) filed a third lawsuit challenging the regulations implementing the No Surprises Act (NSA). TMA’s latest suit before the United States District Court for the Eastern...more

ArentFox Schiff

No More Surprise Medical Bills: Providers Again Challenge No Surprises Act Rulemaking

ArentFox Schiff on

In late September 2022, health care providers in Texas sued the Departments of Treasury, Labor, and Health and Human Services (collectively, the Departments) over a recently issued final rule implementing the federal No...more

Mintz - Employment Viewpoints

HHS, Treasury and Labor Issue More Guidance on the No Surprises Act

Title I of Division BB of the Consolidated Appropriations Act, 2021 (the “Act”), and interim final rules issued by the Departments of Health and Human Services, Treasury and Labor (the “Departments”) in July 2021 (see our...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

Clark Hill PLC

US Departments of Labor, Health and Human Services, and Treasury Issue Final Rules To Clarify Federal Process To Protect Against...

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Final Rules Make Medical Claim Payment Process More Transparent - Final rules issued earlier this month and effective for the Jan. 1, 2022, plan year (the current year for most employer-provided welfare plans) provide details...more

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