New No Surprises Act Guidance Builds On Recent Final Rule

On August 19, 2022, the Departments of Health and Human Services (HHS), Labor, and the Treasury issued a new series of frequently asked questions (FAQs) on a range of topics regarding implementation of the No Surprises Act (NSA). Among other topics, the FAQs address the NSA’s application to plans without a network or with a closed network, international pickup by air ambulance companies, emergency services provided in a behavioral health crisis facility, and notices. The FAQs also address questions related to the insurer transparency rule.

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