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HHS Issues No Surprises Act FAQs in Response to Fifth Circuit Vacatur of Prior Panel Opinion
Reed Smith 
[Guidance Overview] Aug. 22, 2025 "Pending resolution of the Fifth Circuit's en banc review of the case, issuers and plans that are making a good faith effort to calculate their QPAs using the 2021 and 2023 methodologies should be safe from enforcement actions by the Federal agencies. However, once the Fifth Circuit issues its ruling, the QPA calculation methodology could drastically change and the plans and issuers should be ready for that eventuality." MORE >> |
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