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Our Employee Benefits & Executive Compensation Group discusses new guidance for group health plans and insurers on complying with federal gag clause prohibitions and No Surprises Act requirements....more
The Texas Medical Association and additional plaintiffs have brought four Administrative Procedure Act (APA) challenges to the rules and guidance implementing the No Surprises Act (NSA) (termed TMA I, II, III and IV). The...more
As employers work toward annual enrollment and new service contracts for their health plans, it is key to remember one of the changes to enhance disclosure to individuals contained in the “No Surprises Act” and Transparency...more
The May Monthly Minute examines a recent Seventh Circuit decision upholding unambiguous plan language against class action attack, the status of the federal IDR process under the No Surprises Act, and the DOL’s recent...more
The No Surprises Act (the NSA) bans “gag clauses” that prevent disclosure of price or quality information in agreements between health plans and certain service providers. In addition, the NSA requires plan sponsors to attest...more
On February 23, 2023, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) issued new guidance (in the form of FAQs) implementing the No Surprises Act’s prohibition on “gag clauses” in...more
The No Surprises Act (NSA) went into effect Jan. 1, 2022, but since the effective date, there have been numerous updates and changes regarding the NSA and compliance with it. We examine the key NSA 2022 changes and details of...more
Air ambulance services often result in large, unanticipated medical bills for patients. A study by the Government Accountability Office found that in 2017, 69% of air ambulance transports provided to individuals covered by...more
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
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
In one of the biggest attempts by the federal government to combat surprise medical billing, Congress in late 2020 passed the No Surprises Act (NSA), which imposes a host of new transparency and coverage requirements for...more