Proposed Rule Change for No Surprises Act: Implications for Corporations and Law Firms

On September 20, 2023, the US Departments of Health and Human Services (HHS), Labor (DOL) and the Treasury proposed a rule change with potential implications for corporations and law firms dealing with the No Surprises Act’s (NSA’s) federal independent dispute resolution (IDR) process. Read More

The proposed rule, if enacted, would alter existing regulations concerning the two fees associated with the IDR process. These include the administrative fee amount levied by the departments and the ranges for the IDR entity fees for single and batched conflicts.

The IDR process is an essential component of the NSA, intended to protect patients from unexpected medical bills. Under this process, insurance companies and healthcare providers are required to negotiate to settle billing disputes, which can also encompass large corporate bodies that offer employee health benefits.

However, the proposed changes aim to revise the charges incurred during this process. Basically, it could lead to an increase in the federal IDR fees, thereby potentially impacting entities that frequently utilize the IDR process. As such, it potentially holds substantial implications for corporations and law firms.

The proposal has been put forth by legal experts from McDermott Will & Emery. Further understanding of the impending changes and their potential consequences requires careful monitoring and interpretation of ongoing legal developments.