While portions of the federal No Surprises Act (the act or NSA) remain embroiled in litigation, healthcare providers have struggled to comply with various provisions of the act, particularly the disclosure requirements, since its January 1 effective date. On June 23, the Centers for Medicare & Medicaid Services (CMS) released frequently asked questions (FAQs) on the NSA implementation that address a wide range of issues.
While the FAQs do not have the force of law and specifically state that they are not meant to bind the public in any way (unless specially incorporated into a contract), they do provide a good general summary of the technical legal standards and offer guidance on common questions that have arisen since the effective date, including:
The FAQs are helpful for providers as they decipher the complicated requirements of the act.
As the legal guidance continues to be released, providers will want to periodically check the webpage CMS has created to compile all guidance on the act, found here.
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Day Pitney Cybersecurity, Healthcare and Technology (C.H.A.T.) Newsletter - September 2022
Day Pitney Cybersecurity, Healthcare and Technology (C.H.A.T.) Newsletter - September 2022
Day Pitney Cybersecurity, Healthcare and Technology (C.H.A.T.) Newsletter - September 2022
Day Pitney Cybersecurity, Healthcare and Technology (C.H.A.T.) Newsletter - September 2022
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