No Surprises Act Interim Final Rules Include Model Notice; Prohibits Balance Billing for Out-of-Network Emergency Care and Air Ambulances

The Departments of Health and Human Services (HHS), Labor and Treasury (collectively“Departments”) released the Interim Final Rule “Requirements Related to Surprise Billing; Part I”. This rule is the first round of sub regulatory guidance written in response to the No Surprises Act passed as part of the Consolidated Appropriations Act. The Act establishes protections from surprise…

The Impact of the Consolidated Appropriations Act of 2021 on the Mental Health Parity Rules

The Consolidated Appropriations Act, 2021 (CAA) was enacted on Dec. 27, 2020. The CAA includes a $900 billion coronavirus relief package that provides funding to individuals and businesses. Within the CCA, there is a somewhat overlooked but important provision that affects group health plans because it requires such plans to prepare a report with specific information demonstrating…