News & Analysis as of

Surprise Medical Bills Consolidated Appropriations Act (CAA) Health Insurance

Ballard Spahr LLP

Courts Split on Enforcement of No Surprises Rules

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The Fifth Circuit and the Federal District Court of Connecticut have issued conflicting decisions on whether service providers may sue to enforce arbitration awards under the No Surprises Rules in the Consolidated...more

Ballard Spahr LLP

Surprise, Surprise! No Surprise Billing Regulations Upheld

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The Fifth Circuit Court of Appeals recently upheld regulations defining the qualifying payment amount (QPA). The QPA is a key factor in determining how much individuals and health plans must pay out-of-network providers in...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

Ballard Spahr LLP

No Surprises, But Much Uncertainty: The Status of CAA Billing Rules

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Summary - The rules in the Consolidated Appropriations Act that aim to eliminate much of the surprise from billings by out-of-network providers in particular situations are the subject of continued controversy....more

Jackson Lewis P.C.

Court Strikes Down a Portion of the No Surprises Act Interim Regulations

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While health plans, insurers, and providers are busy understanding and implementing the new requirements under the No Surprises Act, a U.S. District Court recently vacated an essential portion of the interim regulations...more

Ballard Spahr LLP

Understanding the New 'No Surprises Rules'

Ballard Spahr LLP on

Summary - The following is the first publication in our series on the Consolidated Appropriations Act 2021 (CAA) and transparency regulations. It concerns the rules designed to prevent surprise billings. These No Surprises...more

Foley & Lardner LLP

Government Issues No Surprises Act Interim Final Rule with Comment Period (Part II)

Foley & Lardner LLP on

On September 30, 2021, the U.S. Departments of Health and Human Services (HHS), Labor and Treasury (collectively, the Departments) along with the Office of Management and Budget released “Requirements Related to Surprise...more

Proskauer - Health Care Law Brief

The Surprises Continue: The Biden Administration Delays Implementation of Certain Provisions of the No Surprises Act and...

In a FAQ published on August 20, 2021, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) significantly delayed implementation of statutory requirements on surprise billing...more

McAfee & Taft

New health plan guidance regarding transparency regulations and last year’s budget act

McAfee & Taft on

Late last Friday afternoon, the Departments of Labor, Health and Human Services, and the Treasury issued some new frequently asked questions (FAQs) regarding implementation of the transparency in coverage (TIC) regulations...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

New Guidance Delays Some Key CAA and Other Health Benefit Effective Dates

New regulatory guidance from three federal agencies that enforce private-sector benefits laws will make employers’ daunting 2021 health benefit to-do lists slightly - but only slightly - more manageable heading into 2022....more

Polsinelli

New Federal Surprise Billing Prohibition and Its Implication on State Laws

Polsinelli on

On July 1, 2021, the Biden-Harris Administration issued “Requirements Related to Surprise Billing; Part 1,” an interim final rule (IRM) that will restrict health care providers and facilities from sticking patients with...more

Holland & Hart - The Benefits Dial

I Can’t Go For That, No Balance Billing

The Consolidated Appropriations Act of 2021 (“CAA”) established, among other things, new protections from surprise billing and excessive cost-sharing for consumers receiving health care items and services (“No Surprises...more

Robinson+Cole ERISA Claim Defense Blog

Implementing Regulations for The No Surprises Act: Part I

On July 1, 2021, the Departments of Health and Human Services (HHS), Labor, and Treasury (together, “the Departments”), and the Office of Personnel Management, issued Requirements Related to Surprise Billing; Part I (Interim...more

Groom Law Group, Chartered

Surprise! Tri-Agencies Meet Deadline with First Set of Surprise Billing Rules, With More to Come

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (“DOL”) (collectively, the “Departments”), released the interim final...more

Bradley Arant Boult Cummings LLP

No More Surprises? New Rule on Surprise Medical Bills

The U.S. Departments of Health and Human Services, Labor, and Treasury, and the Office of Personnel Management have issued "Requirements Related to Surprise Billing; Part I," an interim final rule to implement the No...more

Holland & Knight LLP

HHS Issues Interim Final Rule Implementing Certain Provisions of the No Surprises Act

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The U.S. Departments of Health and Human Services (HHS), Labor and Treasury, along with the Office of Personnel Management, on July 1, 2021, issued a much-anticipated Interim Final Rule with Comment Period (IFC) –...more

Morgan Lewis

Consolidated Appropriations Act, 2021: Health and Welfare Provisions

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The Consolidated Appropriations Act, 2021 (Act) that was signed into law on December 27, 2020 contains provisions impacting employer sponsored group health plans, including protecting group health plan participants from...more

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