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Course Details

This CLE webinar will provide employee benefits counsel, plan sponsors, and administrators with a detailed analysis of the current regulatory framework under the No Surprises Act (NSA). The panel will examine good faith estimate requirements, surprise billing prohibitions, notice and consent requirements, and the payment process under the NSA. In light of ongoing litigation and agency guidance, the program will focus in depth on the qualifying payment amount (QPA) methodology and the independent dispute resolution (IDR) process, including regulatory modifications, enforcement discretion, and practical compliance challenges.

Faculty

Description

The NSA, enacted as part of the Consolidated Appropriations Act of 2021, was initially implemented through interim final rules and later through final rules addressing core provisions such as surprise billing protections, patient disclosures, notice and consent, and the Qualifying Payment Amount (QPA) methodology. Since then, the regulatory landscape has been significantly reshaped by ongoing litigation, particularly the series of Texas Medical Association (TMA) decisions. These rulings have altered how the QPA is calculated and applied. The ripple effects have disrupted the structure of the federal IDR framework, which continues to experience high dispute volumes and operational strain. At the same time, regulators have placed renewed emphasis on disclosure and cost-sharing requirements

 

Given this unsettled environment, benefits counsel and plan administrators must understand both the statutory baseline and the evolving agency interpretations to ensure compliance. 

 

Listen as our panel discusses surprise billing prohibitions, notice and consent requirements, and the payment process under the NSA. The panel will also discuss the qualifying payment amount and IDR processes under the final rules.

Outline

I. Overview and Background of the NSA

    A. Surprise billing prohibitions and statutory framework

    B. Notice and consent requirements for out-of-network services

    C. Enforcement environment, including impact of TMA litigation

II. Implementation of the Final Rule and Subsequent Developments

    A. QPA calculation and disclosure requirements 

    B. Federal IDR process

III. Best Practices for Compliance

Benefits

The panel will discuss these and other key issues:

  • What are the regulatory requirements under Parts I and II of the Final Rule, and how have subsequent court rulings modified those obligations?
  • What are the challenges with surprise billing prohibitions, notices, and disclosures for plan sponsors and administrators?
  • What are the critical components of the most recent final rule and agency guidance?
  • What is the current QPA disclosure framework?
  • How do you navigate the federal IDR process?