The No Surprises Act Final Rule: Implications for State Regulators

Stakeholder Perspectives and Feedback on Health Equity in the 2023 Notice of Benefit and Payment Parameters


By Jack Hoadley, Kevin Lucia, JoAnn Volk

On August 19, the federal government issued a new final rule to further implement the federal independent dispute resolution (IDR) process under the No Surprises Act (NSA). The federal IDR process will be used to resolve disputes between out-of-network providers and self-funded plans as well as insurers in states that do not have an existing payment resolution mechanism; the federal IDR process will generally not apply to insurers in states with a “specified state law.”

In a new Expert Perspective for the State Health & Value Strategies project, CHIR’s Jack Hoadley, Kevin Lucia, and JoAnn Volk review the final rule and discusses its implications for state balance billing protections and oversight. Read the full article here.

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