News & Analysis as of

No Surprises Act (NSA) Department of Labor (DOL) Administrative Procedure Act

King & Spalding

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

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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

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: Biden Administration Finalizes Rule Resetting Administrative Fees for No Surprises Act...

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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

King & Spalding

CMS Proposes 200% Fee Hike to No Surprises Act IDR Fees

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On September 20, 2023, the Departments of Health and Human Services, Labor, and the Treasury (the Departments) announced the Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee...more

McDermott+

Special Report - No Surprises Act Update: The TMA III Decision - August 2023

McDermott+ on

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

King & Spalding

No Surprises Act Developments – Reduced IDR Fee Schedule and Government Litigation Win

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Last week, a number of developments arose stemming from the various lawsuits challenging the No Surprises Act. First, in response to the Eastern District of Texas’ order vacating the administrative fee guidance for the...more

McDermott Will & Schulte

District Court Vacates Provisions of No Surprises Act Final Rule

On February 6, a US district court in Texas vacated provisions of the No Surprises Act final rule related to the independent dispute resolution (IDR) process for determining payment for out-of-network services....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

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

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