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Federal Surprise Billing Rules: The First Round Arrives | Lexology

BY Hall Render Killian Heath & Lyman PC

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 not address the independent dispute resolution process, price transparency and comparison tools, reporting requirements for health plans and providers and enforcement mechanisms. The Departments indicated that such provisions would be addressed in future rulemakings, yet to come in 2021. The Act will go into effect for health insurance plan years beginning on January 1, 2022. Comments on the IFR are due by 5:00 P.M. EST on September 7, 2021. Comments on the model notice and disclosure forms are due on August 12, 2021.


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