UPDATE: No Surprises Here – Portions of the No Surprises Act Regulations...
The No Surprises Act (the Act) continues to bump through its initial implementation phase. As we discussed in our prior blog, out-of-network physicians and facilities (OON Providers), and their allies,...
View Article“The No Surprises Act” a/k/a “The Act that Continues Surprising Providers”
The No Surprises Act (the “Act”) continues muddling through its implementation period. We have discussed the Act in prior posts, and most recently on March 8, 2022. The surprises have continued, with...
View ArticleHealthcare Cyber Insurance? Fortify Your Defenses
Healthcare breaches, including ransomware attacks, continue to increase. As a result, many healthcare organizations seeking cyber coverage to help defray the costs associated with a ransomware attack...
View ArticleALERT! Your COVID-19 Policies and Procedures Need a BOOSTER!
Employers who are conducting automatic COVID-19 testing of employees or gathering test results of employees’ families should beware: the Equal Employment Opportunity Commission (“EEOC”) has issued new...
View ArticleMore Turbulence for the No Surprises Act Thanks to Air Ambulance Providers
Given the trajectory, it is no longer surprising that the No Surprises Act (the Act) continues its turbulent path through implementation. The U.S. District Court for the Eastern District of Texas, on...
View ArticleFinally, More Certainty and Fewer Surprises – Final Rules Issued Under the No...
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...
View ArticleStop – Go – Stop Again – Now GO… Surprised by the No Surprises Act?
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...
View ArticleSurprise… No Surprises Act Arbitration Is Too Expensive
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...
View ArticleTHE NO SURPRISES ACT: Hoping for an End to the Surprises
By looking at the events that have transpired since the Consolidated Appropriations Act, 2021, which includes the No Surprises Act (the Act), was signed into law, it is clear that the Departments of...
View ArticleCompliance Officers: Read the New OIG General Compliance Program Guidance!
The Office of Inspector General of the U.S. Department of Health and Human Services (the OIG) recently released an updated General Compliance Program Guidance document (GCPG). The GCPG has been...
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