During a National Stakeholder Call on January 18, 2022, Ellen Montz—Deputy Administrator and Director of the Center for Consumer Information and Insurance Oversight (CCIIO) at the Centers for Medicare and Medicaid Services (CMS)—announced that CMS had begun publishing state-specific letters (the “Enforcement Letters”) detailing anticipated Federal and state responsibilities with respect to enforcement of the No Surprises Act (NSA) on the CCIIO website. Although CCIIO has yet to publish Enforcement Letters for a minority of states,[1] the Enforcement Letters that have been published provide critical details regarding how the NSA intersects with existing state laws and CMS’s expectations regarding NSA enforcement in each state.
On September 30, 2021, the federal Departments of Treasury, Labor, and Health and Human Services issued “Requirements Related to Surprise Billing; Part II,” the second in a series of interim final regulations (the “Second NSA Rules”) implementing the No Surprises Act (“NSA”). This new federal law became effective for services on or after January 1, 2022.
Blog Editors
Recent Updates
- Podcast: The Down-Low on Data for Value-Based Enterprises and Their Participating Providers – Diagnosing Health Care
- Second Circuit Affirms Denial of Preliminary Injunction in Challenge To N.Y. Law Restricting Weight Loss and Muscle Building Supplement Sales to Minors
- The DOJ’s Bulk Sensitive Data Rule and Your Obligation to “Know Your Data”
- Eliminating the GRAS Pathway: An Update
- Brand Licensing in Health Care: An Overview for Hospitals