Articles and Blogs

On August 26, 2022, the U.S. Departments of Health and Human Services, Labor, and the Treasury (collectively, the “Departments”) published their first final rule (“Final Rule”) implementing certain requirements of the No Surprises Act. This third round of rulemaking is narrow in scope and generally: (1) Responds to stakeholder comments related to the federal... READ MORE

As of January 1, 2022, providers and facilities must comply with a number of requirements established by the No Surprises Act (the “Act”). CMS recently published several resource documents, as described below, to provide further clarity surrounding implementation of the Act and help providers and facilities better understand their respective compliance obligations. Background The... READ MORE

On December 9, 2021 the American Hospital Association (“AHA”), American Medical Association (“AMA”) along with other health care providers filed a complaint in the United States District Court for the District of Columbia challenging part of the Departments of Health and Human Services (“HHS”), Labor and Treasury and the Office of Personnel Management (collectively,... READ MORE

On September 30, 2021, the Departments of Health and Human Services (“HHS”), Labor, and Treasury and the Office of Personnel Management (collectively, the “Departments”) published the second interim final rule implementing certain provisions of the No Surprises Act (“Part II of the IFR”). Part II of the IFR addresses key aspects of the No... READ MORE

On August 20, 2021, the Departments of Labor, Health and Human Services and the Treasury (collectively, the “Departments”) announced through a set of frequently asked questions (“FAQs”) that the Departments will defer enforcement of certain provisions of the No Surprises Act (the “Act”). This comes as welcomed news for health plans and providers alike... READ MORE

On July 1, 2021, the Departments of Health and Human Services (“HHS”), Labor and Treasury and the Office of Personnel Management (collectively, the “Departments”) published a much anticipated interim final rule (“IFR”) implementing certain provisions of the No Surprises Act (the “Act”). While the IFR addresses some key aspects of the Act, it does... READ MORE