Compliance Stuff

Congress enacted the No Surprises Act ( NSA ) to protect patients from unexpected medical bills . A central pillar of the  NSA  is its independent dispute resolution ( IDR ) process, under which payers and providers can submit disputed claims to binding arbitration. Since the IDR process under the NSA began in April 2022, hundreds of thousands of claims have been submitted. As arbitrators have handed down awards, largely in favor of providers, a critical question has emerged — are these final and binding judgments privately enforceable? Two recent federal decisions, one from the District of Connecticut and one from the Fifth Circuit, have reached opposite conclusions. Guardian Flight LLC v. Aetna Life Ins. Co. , No. 3:24-cv-680-MPS (D. Conn. May 14, 2025):   Private Right of Action Exists In  Guardian Flight LLC v. Aetna Life Insurance Co ., the District of Connecticut addressed whether air ambulance providers could bring suit in court to enforce unpaid or late-...

  As employers look toward open enrollment for their group health plans, now is a good time to review action items needed for those plans by year-end, as well as upcoming deadlines in the near future. While fully-insured health plans generally have their compliance obligations satisfied by the insurer, self-insured health plans usually rely on the employer or the plan's third-party administrator (TPA) to meet the compliance requirements. Below is a brief summary of items that employers should be aware of for their health plans and, as appropriate, we have delineated when such compliance is limited only to self-insured health plans. Capitol Bridge Health Plan: Effective 03/01 - 02/28 TDB Communication, Inc. Health Plan: Effective 07/01 - 06/30 Capitol Bridge Health Services Health Plan: Effective 07/01 - 06/30 Capitol Bridge Puerto Rico: Effective (TO BE DETERMINED) 1. HIPAA Privacy Extends Special Protections to Reproductive Health Care: Employer Action Required by 12/23/24 Earlier...