Updated No Surprises Act and IDR Guidance

Wendy Lopez

Recent developments in healthcare legislation have brought changes to the No Surprises Act’s independent dispute resolution (IDR) process. Issued by the Departments of Labor, the Treasury, and Health and Human Services (HHS), FAQ Part 62 provides essential updates regarding the qualifying payment amount (QPA) calculation methodology and the disclosure requirements for out-of-network (OON) air ambulance services. Moreover, the federal IDR portal has reopened, streamlining the resolution of billing disputes. The No Surprises Act Overview The No Surprises Act, a part of the Consolidated Appropriations Act, 2021, aims to protect patients from surprise medical bills. It places limits on out-of-network cost-sharing and bans balance billing in various situations, such as emergency… Read More

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Court Vacates Coupon Cost-Sharing Rule

Wendy Lopez

On September 29, 2023, a significant legal development occurred that could affect how health insurance carriers and group health plans handle manufacturer coupons for prescription drugs. The District Court for the District of Columbia vacated a rule issued by the Department of Health and Human Services (HHS) that allowed, but did not mandate, the inclusion of manufacturer coupons in calculating the cost-sharing for health plans. In this blog post, we’ll explore the background of this issue, the 2019 HHS rule, and the subsequent legal decisions that have led to this recent development. HHS’s 2019 Rule In 2019, HHS issued a rule to clarify this matter. The rule stated that plans… Read More

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