[07/08/24]
Posted on July 8, 2024 in Health Law News
Published by: Hall Render
Recently, the Departments of Health and Human Services, Labor and the Treasury (collectively, the “Departments”) issued an extension for health care providers impacted by the Change Healthcare cyberattack to submit out-of-network payment disputes through the federal No Surprises Act (“NSA”) independent dispute resolution (“IDR”) process. The NSA IDR process permits providers and facilities that... READ MORE
Tags: idr, Independent Dispute Resolution, No Surprises Act, NSA
[01/16/24]
Posted on January 16, 2024 in Health Law News
Published by: Hall Render
On December 21, 2023, the Departments of Health and Human Services, Labor and the Treasury (collectively, “the Departments”) released a final rule that sets the applicable fees for participating in the No Surprises Act’s (“NSA”) Independent Dispute Resolution (“IDR”) process. The new administrative fee and IDR entity fee ranges established under the final rule... READ MORE
Tags: IDR Fees, Independent Dispute Resolution, No Surprises Act
[11/17/23]
Posted on November 17, 2023 in Health Law News
Published by: Hall Render
On November 3, 2023, the Departments of Health and Human Services, Labor, and the Treasury (collectively, “the Departments”) released a proposed rule that would implement significant administrative and technical changes to the No Surprises Act’s (“NSA”) Independent Dispute Resolution (“IDR”) process (the “Proposed Rule”). These changes aim to create a more efficient IDR process... READ MORE
Tags: IDR Process, Independent Dispute Resolution, No Surprises Act
[10/05/23]
Posted on October 5, 2023 in Health Law News
Published by: Hall Render
On September 26, 2023, the Departments of Health and Human Services, Labor, and the Treasury (collectively, “the Departments”) released a proposed rule that would again change the administrative fees for participating in the No Surprises Act’s (“NSA”) Independent Dispute Resolution (“IDR”) process. The proposed rule responds to the August 3, 2023 ruling from the... READ MORE
Tags: IDR Fees, Independent Resolution Process, No Surprises Act
[08/28/23]
Posted on August 28, 2023 in Health Law News
Published by: Hall Render
On August 3, 2023, the U.S. District Court for the Eastern District of Texas (the “Court”) concluded that the Department of Health and Human Services, the Department of Labor and the Department of the Treasury (collectively “the Departments”) violated statutory rulemaking procedure and therefore vacated two aspects of the Departments’ guidance related to the... READ MORE
Tags: Administrative Procedure Act, Independent Resolution, No Surprises Act
[02/20/23]
Posted on February 20, 2023 in Health Law News
Published by: Hall Render
More than one year after its effective date, the Centers for Medicare and Medicaid Services (“CMS”) has started investigating consumer complaints alleging provider violations of the No Surprises Act. The No Surprises Act generally: (1) prohibits balance billing for out-of-network emergency services, non-emergency services provided by out-of-network providers at in-network facilities and air ambulance... READ MORE
Tags: Centers for Medicare and Medicaid Services, Documentation, No Surprises Act, Provider Compliance Requirements
[12/05/22]
Posted on December 5, 2022 in Health Law News
Published by: Hall Render
The Centers for Medicare and Medicaid Services (“CMS”) published FAQ guidance on December 2, 2022, indefinitely extending the current enforcement discretion for non-compliance with the No Surprises Act requirement that Good Faith Estimates (“GFEs”) for uninsured or self-pay patients include expected charges from co-providers or co-facilities until future rulemaking is issued. Since January 1,... READ MORE
Tags: GFE, Good Faith Estimate, hhs, No Surprises Act
[11/03/22]
Posted on November 3, 2022 in Health Law News
Published by: Hall Render
In October 2021, the Texas Medical Association (“TMA”) sued the Departments of Health and Human Services (“HHS”), Labor and Treasury and the Office of Personnel Management (collectively, the “Departments”) challenging an Interim Final Rule which required certified independent dispute resolution (“IDR”) entities to employ a presumption in favor of the qualifying payment amount (“QPA”)... READ MORE
Tags: independent dispute resolution process, No Surprises Act, Texas Medical Association
[08/31/22]
Posted on August 31, 2022 in Health Law News
Published by: Hall Render
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
Tags: No Surprises Act, QPA, qualifying payment amount
[01/25/22]
Posted on January 25, 2022 in Health Law News
Published by: Hall Render
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
Tags: No Surprises Act, Surprise Billing