December 3, 2021

Volume XI, Number 337

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Getting Ready for the No Surprises Act [VIDEO]

Is your organization ready for the No Surprises Act (NSA)? The law goes into effect January 1, 2022, and contains a new federal ban on surprise billing as well as new disclosure requirements.

The NSA applies to certain payors, providers, facilities, and ancillary service entities that support patients who receive emergency services or other non-emergency services at certain facilities, such as hospitals, hospital outpatient departments, and ambulatory surgical centers.

What does this mean for you?

  • Health care businesses should design a detailed “operationalized” NSA compliance program now but stay flexible as additional regulations are issued.

  • If you have operations in multiple states, assess whether state laws may apply and how they will interact with the federal law.

  • Calculate your median contracted rates for common services in each sector for billing guidance.

  • Ancillary service providers, in particular, must determine how to obtain the necessary information to help determine if federal protections apply to services they provide to patients in facilities in which they are not physically located.

 

©2021 Epstein Becker & Green, P.C. All rights reserved.National Law Review, Volume XI, Number 327
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About this Author

Helaine I. Fingold, Epstein Becker Green, Health Care, life sciences
Senior Counsel

HELAINE I. FINGOLD is a Senior Counsel in the Health Care and Life Sciences practice, in the Baltimore office of Epstein Becker Green. She has more than 20 years of broad health law and regulatory experience, including prior government experience in both the legislative and executive branches of the federal government.

Ms. Fingold:

Advises on issues involving the Medicare Program Parts A, B, C, and D, Medicare Innovations, Medicare Dual Eligibles, Medicaid, and Veterans' health care programs

...

443-663-1354
Member of the Firm

Bob Hearn believes in making legal work count and never losing sight of every task’s value proposition. He uses creative but practical strategies to resolve disputes, manage liabilities, and untangle regulatory and compliance challenges in an efficient yet durable manner. That’s why clients trust him when complex and potentially costly matters require attention.

Bob’s practice, while legally diverse—covering both litigation and regulatory, compliance, and business counseling work—has a strong focus on the health care and life science sector. Bob has dedicated a significant part of...

727-346-3767
Alexis Boaz Health Care & Life Sciences Attorney Epstein Becker & Green Washington, DC
Associate

Alexis Boaz is an Associate in the Health Care and Life Sciences practice, in the Washington, DC, office of Epstein Becker Green. She will be focusing her practice on fraud and abuse, transactional, regulatory, and compliance matters.

Ms. Boaz received her Juris Doctor from The George Washington University Law School (“GW”), where she was a student attorney for the Health Insurance Counseling Project and a recipient of the President’s Volunteer Service Award and GW Excellence in Service Award in recognition of her pro bono work. She also earned a Master of Public Health in Health...

202-861-1889
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