On Sept. 30, 2021, the Department of Health and Human Services, Department of Treasury, Department of Labor, and the Office of Personnel Management released an Interim Final Rule (Part 2 Surprise Billing Regulations) that implements portions of the No Surprises Act (“NSA”), legislation that protects consumer from surprises medical bills and regulates balance billing by out-of-network providers.
This interim final rule, the second interim final rule issued on the NSA, addresses the independent resolution (IDR) process, good faith estimates for uninsured or self-pay individuals, and the patient-provider dispute resolution process.
We have reviewed Part II of the NSA Rules and there is no further guidance on provisions that directly impact our S365 Transparency Platform, such as further guidance on the provider directory update requirements. The rule is mostly focused on the Independent Resolution Process (IDR) for settling payment disputes between providers and health plans. For now, the most comprehensive guidance on the NSA and the transparency requirements is located in the FAQ that was published in August of 2021.
The “Biden Administration Issues Additional No Surprises Act Guidance in New Interim Final Rules” legal bulletin from JD Supra provides a good summary of the latest rules.