On October 30, 2024, the United States Court of Appeals for the Fifth Circuit (Fifth Circuit) issued an opinion in Texas Medical Association, et al. v. United States Department of Health and Human Services et al., Case No. 23-40605 __ (TMA III). The Fifth Circuit partially reversed a decision of the U.S. District Court for the Eastern District of Texas (the District Court). The Fifth circuit partially reversed the District Court’s holding that vacated certain provisions of the regulations and guidance under the No Surprises Act related to the methodology for calculating the qualifying payment amount (QPA). It also affirmed the District Court’s vacatur of certain deadline provisions and affirmed the District Court’s holding as to the disclosure requirements. The Departments and OPM are reviewing the Fifth Circuit’s decision and intend to issue further enforcement guidance in the near future.
Ending Surprise Medical Bills
Learn how providers, facilities, plans and issuers can comply with surprise billing protections and resolve out-of-network payment disputes
No Surprises Act
Policies & resources
Review rules and fact sheets on what No Surprises rules cover, and get additional resources with more information.
Resolving out-of-network payment disputes
Learn about out-of-network payment disputes between providers and health plans and how to start the independent dispute resolution (IDR) process, apply to become a certified independent dispute resolution entity, or submit a petition on an applicant or to revoke certification of a current IDR entity.
Consumers and consumer advocates
Learn about rights and protections for consumers to end surprise bills and remove consumers from payment disagreements between their providers, health care facilities and health plans.
Page Last Modified:
11/01/2024 05:52 PM