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No Surprises Act Guidance for Health Plans: Final Rules, IDR Process, Qualifying Payment Amounts, Disclosures

Recording of a 90-minute premium CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
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Conducted on Wednesday, November 2, 2022

Recorded event now available

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This CLE webinar will provide employee benefits counsel, plan sponsors, and administrators guidance on key provisions and requirements of the final rules implementing the No Surprises Act (NSA). The panel will discuss the good faith estimate requirements for uninsured or self-pay patients, surprise billing prohibitions, notice and consent requirements, and the payment process under the Act. The panel will also provide a deep dive into the qualifying payment amount (QPA), and independent dispute resolution (IDR) processes under the final rules.


On Aug. 19, 2022, the U.S. Departments of Health and Human Services (HHS), Labor (DOL), and Treasury (IRS) issued final rules modifying the NSA. Benefits counsel and administrators must recognize the impact of these changes and grasp a complete understanding of the challenges under the final rule to ensure compliance.

The NSA is included in the Consolidated Appropriations Act of 2021 (CAA). Shortly after the enactment of the CAA, interim final rules were issued to implement core aspects of the NSA, providing requirements related to surprise billing, disclosures, notices, and other critical aspects of the NSA.

The final rule significantly modifies key provisions of the NSA, providing more guidance on (1) qualifying payment amounts that plans and issuers must disclose to providers and facilities; (2) the determination of out-of-network rates through the federal IDR process; and (3) expands the information that a certified IDR entity must provide in its written payment determinations.

Listen as our panel discusses surprise billing prohibitions, notice and consent requirements, and the payment process under the NSA. The panel will also discuss the qualifying payment amount and IDR processes under the final rules.



  1. Overview and background of the NSA
    1. Surprise billing prohibitions
    2. Notice and consent
    3. Enforcement
  2. Final rule implementing the NSA
    1. QPA disclosure requirements
    2. Federal IDR process
  3. Best practices to ensure compliance


The panel will discuss these and other key issues:

  • What are the regulatory requirements under Part I and Part II of the Interim Final Rule?
  • What are the challenges with surprise billing prohibitions, notices, and disclosures for plan sponsors and administrators?
  • What are the critical components of the recently issued final rule under the NSA?
  • What are the QPA disclosure requirements?
  • How do you navigate the federal IDR process?


Andrew, Laura
Laura Miller Andrew

Smith Gambrell & Russell

Ms. Andrew advises clients in all major aspects of employee benefits including qualified and nonqualified plans, IRS...  |  Read More

Datlow, Milanna
Milanna Datlow

Robinson & Cole

Ms. Datlow is a member of the Managed Care + Employee Benefit Litigation Group. She has experience defending group...  |  Read More

Flynn, Virginia
Virginia B. Flynn

Troutman Pepper Hamilton Sanders

Ms. Flynn is a partner in the firm’s Consumer Financial Services practice and specifically within...  |  Read More

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