News & Analysis as of

No Surprises Act (NSA) Rulemaking Process

Husch Blackwell LLP

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

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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

King & Spalding

Congressmembers Send Letter to Departments Raising Provider Concerns with No Surprises Act Implementation

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On March 18, 2024, thirty-nine (39) members of the United States House of Representatives sent a letter urging federal agencies to finalizing rulemaking regarding the implementation of the No Surprises Act. The letter,...more

ArentFox Schiff

No More Surprise Medical Bills: Biden Administration Issues New Surprise Billing Rulemaking Proposing Batching and Procedural...

ArentFox Schiff on

*This is the 12th article in a series analyzing the No Surprises Act and its implementation. To view the entire series, click here. A link to the proposed rule is here.  As background, Congress passed the Act to prevent...more

King & Spalding

Agencies Issue Informal No Surprises Act IDR Guidance on Batching and Air Ambulance Disputes

King & Spalding on

On November 28, 2023, the Departments of Health and Human Services, Labor, and the Treasury (the Departments) issued two sets of FAQs on aspects of the No Surprises Act (NSA) Independent Dispute Resolution Process (IDR...more

McDermott+

Departments Propose Broader Batching and IDR Process Changes for Surprise Billing Claims

McDermott+ on

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

ArentFox Schiff

No More Surprise Medical Bills: Biden Administration Issues New Rule Governing Arbitration Fees and Takes First Step to Restarting...

ArentFox Schiff on

On September 21, 2023, the US Departments of Treasury (DOT), Labor (DOL), and Health and Human Services (HHS) (the Departments) issued new rulemaking governing the administrative fee required to access the arbitration process...more

McDermott Will & Schulte

HHS, DOL and Treasury Issue a Proposed Rule Increasing Federal IDR Fees

On September 20, 2023, the US Departments of Health and Human Services (HHS), Labor (DOL) and the Treasury (collectively, the departments) issued a proposed rule related to the No Surprises Act’s (NSA’s) federal independent...more

King & Spalding

Provider Victory in Latest No Surprises Act Litigation Overturns QPA Rules

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On August 24, 2023, Judge Kernodle of the Eastern District of Texas issued a fourth judgment overturning additional aspects of the No Surprises Act (NSA) rulemaking and guidance. This latest decision vacated aspects of...more

McDermott+

Implementation of the No Surprises Act Is Full of Surprises: What We Do and Don’t Know

McDermott+ on

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

King & Spalding

Federal Court Vacates 600% Fee Hike to No Surprises Act IDR Fees

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On August 3, 2023, the Texas Medical Association (TMA) was granted summary judgment in its challenge to (1) the $350 CY 2023 administrative fee for the No Surprises Act’s Independent Dispute Resolution (IDR) process and (2) a...more

Ankura

The Department of Justice’s Withdrawal of Three Antitrust Statements and the Impact on Health Care Organizations

Ankura on

On February 3, 2023, the Department of Justice Antitrust Division (DOJ) announced the withdrawal of three policy statements that have long guided the information exchanges as well as the related enforcement in the healthcare...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: Texas Court Again Vacates Arbitration Provisions of Surprise Billing Rule

ArentFox Schiff on

On February 6, 2023, health care providers scored a second significant victory when a federal court in Texas again vacated portions of the Biden Administration’s rules governing the arbitration procedures to resolve surprise...more

McDermott Will & Schulte

NSA Update: HHS Indefinitely Delays Co-Provider, Co-Facility Requirements for Good Faith Estimates

McDermott Will & Schulte on

On December 2, 2022, the US Department of Health and Human Services (HHS) issued an FAQ announcing that it will not enforce the requirement for convening providers and convening facilities to include expected charges for...more

ArentFox Schiff

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

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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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