Publication
SW Benefits Update – Not All Surprises Are Good – Phase I of the Surprise Billing Rules
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By Allison Bans and Carina Arellano [1] |
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On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (collectively the “Departments”) issued the interim final rule “Requirements Related to Surprise Billing; Part I” (the “IFR”), which is the first phase of regulations implementing the No Surprises Act. The No Surprises Act provides certain protections against surprise medical bills and was signed into law on December 27, 2020 as part of the Consolidated Appropriations Act, 2021 (“CAA”). For more information about the CAA’s impact on employer-sponsored group health plans, see our SW Benefits Update, “2021 Consolidated Appropriations Act Compliance Checklist for Plan Sponsors.” |
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[1] Carina Arellano is a summer associate at Snell & Wilmer |
About Snell & Wilmer
Founded in 1938, Snell & Wilmer is a full-service business law firm with more than 500 attorneys practicing in 16 locations throughout the United States and in Mexico, including Los Angeles, Orange County and San Diego, California; Phoenix and Tucson, Arizona; Denver, Colorado; Washington, D.C.; Boise, Idaho; Las Vegas and Reno, Nevada; Albuquerque, New Mexico; Portland, Oregon; Dallas, Texas; Salt Lake City, Utah; Seattle, Washington; and Los Cabos, Mexico. The firm represents clients ranging from large, publicly traded corporations to small businesses, individuals and entrepreneurs. For more information, visit swlaw.com.
