No Surprises Act Guidance for Health Plans: Final Rules, IDR Process, Qualifying Payment Amounts, Disclosures

BARBRI

This CLE webinar will provide employee benefits counsel, plan sponsors, and administrators guidance on key provisions and requirements of the final rules implementing the No Surprises Act (NSA). The panel will discuss the good faith estimate requirements for uninsured or self-pay patients, surprise billing prohibitions, notice and consent requirements, and the payment process under the Act. The panel will also provide a deep dive into the qualifying payment amount (QPA) and independent dispute resolution (IDR) processes under the final rules.

Description

The final rules that modified the NSA continue to cause compliance issues for plan sponsors and administrators. Benefits counsel and administrators must recognize the impact of these changes and grasp a complete understanding of the challenges under the rule to ensure compliance.

The NSA is included in the Consolidated Appropriations Act of 2021 (CAA). Shortly after the enactment of the CAA, interim final rules were issued to implement core aspects of the NSA, providing requirements related to surprise billing, disclosures, notices, and other critical aspects of the NSA.

The final rule significantly modifies key provisions of the NSA, providing more guidance on (1) qualifying payment amounts that plans and issuers must disclose to providers and facilities; (2) the determination of out-of-network rates through the federal IDR process; and (3) the expansion of information that a certified IDR entity must provide in its written payment determinations.

Listen as our panel discusses surprise billing prohibitions, notice and consent requirements, and the payment process under the NSA. The panel will also discuss the qualifying payment amount and IDR processes under the final rules.

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