News & Analysis as of

Health Care Providers No Surprises Act (NSA)

Husch Blackwell LLP

Colorado Revises Healthcare Regulations for Changes in Ownership, Surprise Billing Disclosures

Husch Blackwell LLP on

The Colorado Department of Public Health and Environment (CDPHE), which oversees the licensure of health facilities in Colorado, has adopted revised rules related to healthcare facility changes of ownership (CHOWs) and...more

Arnall Golden Gregory LLP

Healthcare Authority Newsletter - August 2025 #1

News Briefs - Senators Seek Enforcement of No Surprises Act Good-Faith Estimate - The Senate Committee on Health, Education, Labor and Pensions is asking Health and Human Services Secretary Robert F. Kennedy Jr. and other...more

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

Dentons

Ep. 71 – Good Faith Estimates for Uninsured and Self-Pay Patients

Dentons on

Make sure you’re providing good faith estimates to uninsured & self-pay patients - Under the No Surprises Act, healthcare providers are required to offer Good Faith Estimates (GFEs) to self-pay and uninsured patients...more

Troutman Pepper Locke

Litigation Heats Up Over Air Ambulance Billing Practices Under the No Surprises Act

Troutman Pepper Locke on

There has been a flurry of recent activity in a case originally filed by six air ambulance companies claiming $20 million in unpaid emergency services invoices. ...more

Proskauer - Health Care Law Brief

No Surprises Here! Fifth Circuit Holds NSA Provides No Private Right of Action to Enforce IDR Awards, Deepening Judicial Divide...

In a recently issued opinion, the Fifth Circuit has added yet another chapter to the growing debate over whether providers may seek judicial enforcement of Independent Dispute Resolution (“IDR”) awards issued under the No...more

King & Spalding

Fifth Circuit Finds No Private Right of Action for Providers to Enforce Surprise Billing Awards

King & Spalding on

On Thursday, June 12, 2025, a panel of the United States Court of Appeals for the Fifth Circuit issued two rulings construing parts of the No Surprises Act (NSA) to limit judicial review of arbitration awards issued under the...more

ArentFox Schiff

Federal Courts Divided Over Private Enforcement of ‘No Surprises Act’ Arbitration Awards

ArentFox Schiff on

Congress enacted the No Surprises Act (NSA) to protect patients from unexpected medical bills. A central pillar of the NSA is its independent dispute resolution (IDR) process, under which payers and providers can submit...more

Troutman Pepper Locke

Fifth Circuit Clarifies Enforcement of IDR Awards Under the No Surprises Act

Troutman Pepper Locke on

On June 12, the U.S. Court of Appeals for the Fifth Circuit issued a significant opinion in the case involving Guardian Flight, LLC and Med-Trans Corporation, two air ambulance providers, against the defendant insurance...more

ArentFox Schiff

Dispute Not Resolved: BCBSGA Sues Providers for Alleged Misuse of NSA Arbitration Process

ArentFox Schiff on

On May 27, Blue Cross Blue Shield Healthcare Plan of Georgia, Inc. (BCBSGA) filed a lawsuit in the Northern District of Georgia US District Court, alleging that a group of health care providers, along with their third-party...more

Bass, Berry & Sims PLC

Healthcare Regulatory & Compliance Summit 2025 Recap

Health Policy Fireside Chat: What to Expect from the New Administration - Bill Mathias, Member at Bass, Berry & Sims, engaged in a fireside chat with Colin Roskey, Principal at FHP Strategies, former Deputy Assistant...more

McDermott+

Breaking Down the New No Surprises Act FAQs Post-TMA III

McDermott+ on

On January 14, 2025, the US Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments), along with the Office of Personnel Management (OPM), jointly issued Part 69 of a series of...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

Proskauer - Health Care Law Brief

Post‑Chevron Spotlight: Disproportionate Share Hospital Payments Restored as Texas Hospitals Prevail in Challenge to HHS Exclusion...

In a victory for Texas health care providers, in Baylor All Saints Medical Center dba Baylor Scott & White All Saints Medical Center‑Fort Worth et al. v. Xavier Becerra, case number 4:24‑cv‑00432, the United States District...more

McDermott+

No Surprises Act Implementation Bumpy Period Reaches One-Year Mark

McDermott+ on

We are now in September! And while many folks are thinking about how summer has come and gone so quickly, those following the No Surprises Act implementation process may also be wondering how a whole year has passed since the...more

Ballard Spahr LLP

Fifth Circuit Affirms Invalidity of No Surprises Regulations

Ballard Spahr LLP on

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

Harris Beach Murtha PLLC

Court Rejects IDR Rules in No Surprises Act Case

Out-of-network health providers recently won a huge legal victory when the Fifth Circuit Court ruled that federal guidelines regarding Independent Dispute Resolution (“IDR”) proceedings were unlawfully slanted in favor of...more

Akin Gump Strauss Hauer & Feld LLP

The Health Over Wealth Act Takes Aim at Private Equity Investment in Health Care

Key Points - Congress is increasing oversight and legislative activity related to the role of private equity in health care. Sen. Markey and Rep. Jayapal jointly introduced the Health Over Wealth Act on July 25, which aims to...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

Proskauer - Health Care Law Brief

No Surprises Here!  Divergent Court Rulings Spotlight Ongoing Challenges in No Surprises Act Implementation; Tee Up Split in...

Two District Courts have reached opposite conclusions on the enforceability of arbitration awards under the No Surprises Act (“NSA”). The two decisions, while far from the final word on the subject, highlight the most recent...more

Hall Benefits Law

DOL, HHS, and Treasury Release FAQs about No Surprises Act after TMA III

Hall Benefits Law on

The U.S. Departments of Labor (DOL), Health and Human Services (HHS), and Treasury, along with the Office of Personnel Management (OPM), released FAQs about the implementation of Title I of Division BB of the Consolidated...more

McDermott Will & Schulte

Healthcare Regulatory Check-Up Newsletter | May 2024 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights regulatory activity for May 2024. We discuss several notable cases and enforcement resolutions, including the US Court of Appeals for the District of...more

American Conference Institute (ACI)

[Event] 15th Annual Advanced Forum on Managed Care Disputes and Litigation - May 2nd - 3rd, Chicago, IL

ACI’s Advanced Forum on Managed Care Disputes and Litigation offers an unparalleled learning experience, specifically designed for the MCO legal community. Attend and develop winning legal strategies and business best...more

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