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August 15, 2024
No Surprises Act Update August 2024

The No Surprises Act, specifically the Independent Dispute Resolution (IDR) portal portion, has seen a number of legal disputes over the last year. Recently, a federal court of appeals affirmed one of the Texas court's rulings from last year stating that the government’s rules on how to apply the No Suprises Act failed to follow […]

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June 19, 2024
Amendments to HIPAA to Support Reproductive Health Care Privacy

On April 22, 2024, the government issued a Final Rule modifying the HIPAA Privacy Rule to support reproductive health care privacy. The government created additional protections for reproductive health information because it is particularly sensitive and involves highly personal health care decisions. Changes in the legal landscape have nationwide implications, not only because of their […]

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April 1, 2024
Documenting Anesthesia Time

Start Time: 1) Pre-OR time is scrutinized by the government because most pre-OR anesthesia services are bundled into the base units. There are only 2 types of pre-OR time that are billable, meaning your billed start time is prior to your in-room time:- Administering sedation (or a regional anesthetic) to the patient or - Transporting […]

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March 11, 2024
CMS Data for Last 6 Months of IDR Results in 2023

While there remain challenges in the Independent Dispute Resolution (IDR) portal, the main one being extensive backlogs, the second half of 2023 proved to be positive for providers. The IDR portal is the arbitration process developed by the government pursuant to the No Surprises Act. The purpose of the portal is to provide a process […]

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June 5, 2023
Applicability of the No Surprises Act in the Anesthesia World

The No Surprises Act essentially went into effect on January 1, 2022, but portions of it have been delayed and litigated.  The Act itself can be broken down into two parts.  The first part is the Good Faith Estimates (GFEs), while the second part is the Independent Dispute Resolution (IDR) process.  In this article we […]

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May 26, 2023
Quarterly Compliance Newsletter 3-24-2023

Anti-Kickback StatuteThis federal criminal statute prohibits the exchange of anything of value to induce the referral of business reimbursable by federal health care programs. Examples of prohibited kickbacks include receiving financial incentives for referrals, free or very low rent for office space, or excessive compensation for medical directorships. In 2022, the Department of Justice’s (DOJ) […]

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May 26, 2023
Quarterly Compliance Newsletter 12-20-2022

NO SURPRISES ACT The No Surprises Act is new legislation enacted by CMS. Parts of the Act went into effect January 1, 2022. The purpose of the Act is to protect patients from unknown costs of care and ensure patients have access to information to understand the true costs of healthcare services. The Act consists […]

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May 8, 2023
No Surprises Act IDR Status Update

The Department of Health and Human Services, the Department of Labor, and the Department of the Treasury (the Departments) have released an initial report from the fourth quarter of 2022 covering data from October 1 – December 31, 2022 and a status update on the Federal IDR process for the period from April 15, 2022 […]

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August 25, 2022
HHS and the Labor Department issued the final rules for the No Surprises Act on August 19th, 2022

Here are three things you should be aware of: 1. If a qualifying payment amount is based on a down coded service code or modifier, a plan or issuer must provide with its initial payment: · A statement that the service code or modifier billed by the provider, or facility was down coded. · An explanation of […]

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August 11, 2022
Applicability of the No Surprises Act in the Anesthesia World

The No Surprises Act essentially went into effect on January 1, 2022, but portions of it have been delayed and litigated.  The Act itself can be broken down into two parts.  The first part is the Good Faith Estimates (GFEs), while the second part is the Independent Dispute Resolution (IDR) process.  In this article we […]

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Updates

HHS will not be enforcing co-provider estimates for GFEs on January 1, 2023.
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