An Update on the No Surprises Act

By , and on September 28, 2023
The No Surprises Act (NSA) went into effect in January 2022, and it has subsequently faced plenty of litigation from healthcare providers. States and federal agencies are also examining surprise billing and consumer protection laws related to some provisions of the NSA. The report below provides an in-depth review of NSA litigation, oversight activities, and rulemaking and guidance as we approach Q4 2023. We also share our views on what lies ahead for healthcare providers.

Access the report.

Jeffrey Davis
Jeffrey is a skilled healthcare executive with substantial knowledge of regulatory advocacy and healthcare policies. Jeffrey’s work focuses on issues tied to provider payment and reimbursement as well as quality reporting. He also has significant experience with recent regulatory developments such as the implementation of surprise billing rules. Read Jeffrey Davis's full bio.


Kristen O'Brien
Kristen O’Brien is an accomplished healthcare executive with a deep understanding of regulatory advocacy and healthcare policy efforts. Kristen offers a strong background and a keen eye for solutions to barriers and challenges impacting healthcare clients. With more than 10 years of experience, her work focuses on implementing new laws through the rulemaking process, as well as working with relevant agency officials to develop and improve agency guidance. Read Kristen O’Brien's full bio.


Emily Curran
Emily R. Curran focuses her practice on healthcare regulatory and compliance issues in the managed care space. She counsels both for-profit and non-profit healthcare insurance companies on state and federal policy issues and advises clients on reimbursement issues that come into play when participating in government healthcare programs. Emily also supports the Firm’s transactional work. Read Emily Curran's full bio.

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