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September 30, 2022

Federal surprise billing protections: What employers need to know


The Consolidated Appropriations Act, 2021 (CAA) became law on December 27, 2020 and contained several provisions affecting employee health and benefit plans including the No Surprises Act (the “Act”).

The Act includes a variety of requirements, including the obligation to provide transparency and price comparison tools. We addressed those topics in a separate alert. The largest portion of the Act addresses surprise billing protections that apply to group health plans as of the first plan year beginning on or after January 1, 2022. The Act intends these protections to:

  • Limit the ability of out-of-network (OON) providers to balance bill plan participants; and
  • Create a dispute resolution system between plans and providers (as well as patients and providers).

The Agencies have released additional piecemeal guidance in 2022, including updates to model notices, FAQs, and new final regulations clarifying how to determine the “qualifying payment amount,” discussed in further detail in our guide.