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American Academy of Actuaries Comment Letter to HHS, DOL and Treasury on Possible Agency Actions Related to the No Surprises Act (PDF)
American Academy of Actuaries Link to more items from this source
[Opinion]
June 28, 2021

11 pages. "It is likely that providers and payers will experience higher administrative costs due to the implementation and administration of the Act. These additional costs likely will be passed to customers in higher premiums or plan costs ... A national [independent dispute resolution (IDR)] system could result in very disparate effects, state to state and market to market, depending on underlying conditions.... States will have to decide whether to maintain their approaches or switch to the federal system."

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