"[B]efore 2022 begins employers may want to ... [1] Work with third-party administrators (TPAs) to update plan documents to incorporate new surprise billing rules, implement requirements under new surprise billing rules, and implement an [independent dispute resolution] process. [2] Confirm TPAs will update EOBs to include No Surprises Act surprise billing disclosures. [3] Confirm TPAs can calculate [the qualifying payment amount (QPA)].... [4] Prepare to make publicly available and post on the plan's website a notice regarding balance billing protections."