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August 27, 2021

A Federal Solution to Surprise Billing

This Bulletin is brought to you by AHLA’s Payers, Plans, and Managed Care Practice Group.
  • August 27, 2021
  • Lisa Lucido , Hall Render Killian Heath & Lyman PC
  • Matt Reed , Hall Render Killian Heath & Lyman PC
  • Tiana Korley , University of Michigan

After years of debating a federal “fix” to end surprise billing, Congress enacted the No Surprises Act (Act) on December 22, 2020. The Act is intended to bring greater certainty to providers, payers, and patients regarding out-of-network reimbursement. On July 1, 2021, the Departments of Health and Human Services, Labor, and Treasury and the Office of Personnel Management (collectively, the Departments) published an interim final rule (IFR) implementing certain provisions of the Act. This bulletin provides a high-level summary of the first round of rulemaking. Note that the IFR is not a proposed rule; it is the actual rule unless the Departments make modifications based on the public comments they solicited.

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