The No Surprises Act: A Cost Saving Opportunity for Employer Plan Sponsors
Surprise! What Hospices Need to Know About the No Surprises Act
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
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
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
On October 27, 2023, the US Departments of Health and Humans Services, Labor and the Treasury (the Departments), along with the Office of Personnel Management, issued a proposed rule titled Independent Dispute Resolution...more
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
On August 24, 2023, the United States District Court for the Eastern District of Texas again largely ruled in favor of the Texas Medical Association and other plaintiffs (including air ambulance providers) and vacated certain...more
On August 24, 2023, the U.S. District Court for the Eastern District of Texas issued an opinion and order in Texas Medical Association, et al. v. United States Department of Health and Human Services(“HHS”)(“TMA III”). TMA...more
Providers finally obtained court ordered relief to the $350 administrative fee each party was required to pay as part of the Federal Independent Dispute Resolution (IDR) Process under the No Surprises Act. Until the...more
It’s likely no surprise to anyone who has been following the implementation of the No Surprises Act over the last couple of years that we again find ourselves on an uncertain path. While Regs & Eggs has focused on some of the...more
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
On July 6, 2023, the HHS Office of the Assistant Secretary for Planning and Evaluation (ASPE) released the first of five required annual reports on the impact of the No Surprises Act (NSA) on health care markets (the Report)....more
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
Washington State's Office of the Insurance Commissioner (OIC) is delaying its transition to the federal No Surprises Act (NSA) Independent Dispute Resolution (IDR) process for at least six months. As a result of this...more
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
On February 6, 2023, the United States District Court for the Eastern District of Texas ruled in favor of the Texas Medical Association and vacated portions of the final rule adopted in August 2022 (the “August 2022 Final...more
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
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
Pressure continues to mount on the US Department of Health and Human Services (HHS) to reconsider and revise its August 2022 final rule modifying the No Surprises Act independent dispute resolution (IDR) process. The rule is...more
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
In 2020, Congress passed the No Surprises Act (NSA) in an attempt to protect uninsured patients from surprise billing. Some sections of the NSA became effective on January 1, 2022, while other sections are on hold until...more
We previously noted that the regulations implementing the No Surprises Act (“NSA”) appeared to be inconsistent with the NSA because they seemed to establish the qualifying payment amount (“QPA”) as the appropriate payment...more
On August 19, 2022, the Department of Health and Human Services (HHS), Department of Labor (DOL), and Department of the Treasury (DOT), released “Requirements Related to Surprise Billing: Final Rules” (the Rules). The Rules...more