Breaking Down the New No Surprises Act FAQs Post-TMA III

By Drew Elizabeth McCormick, Jamie Gelfman, Kristen O'Brien, Jeffrey Davis and Abygail Hoey on March 25, 2025

Posted In Employee Benefits, Health and Welfare Plans

On January 14, 2025, the US Departments of Labor, Health and Human Services, and the Treasury, along with the Office of Personnel Management, released Part 69 of a series of FAQs aimed at helping stakeholders understand and comply with the federal No Surprises Act.

This latest set of FAQs focuses on how health plans and issuers should determine the qualifying payment amount and includes updates to disclosure and patient cost-sharing requirements, reflecting the recent rulings by the US District Court for the Eastern District of Texas and the US Court of Appeals for the Fifth Circuit in the case of Texas Medical Association, et al. v. United States Department of Health and Human Services, et al.

Drew Elizabeth McCormick
Drew Elizabeth McCormick maintains a general health industry and regulatory practice. Drew advises health care clients on a wide variety of health care regulatory issues, including Medicare and Medicaid regulations, the Federal Anti-Kickback Statute, Ethics in Patient Referral Law, False Claims Act and Health Insurance Portability and Accountability Act (HIPAA), as well as state fraud and abuse laws, privacy laws, licensure regulation, research regulation, and health care compliance matters. Drew also has experience counseling clients who are undergoing government audits and investigations. Read Drew Elizabeth McCormicks' full bio.

Jamie Gelfman
Jamie Gelfman is board certified in health law by the Florida Bar Board of Legal Specialization and Education and is certified in healthcare compliance (CHC) by the Society of Corporate Compliance and the Health Care Compliance Association. Jamie works with healthcare clients on the full scope of legal issues that shape their business strategies. She is deeply experienced in regulatory, compliance, reimbursement and licensure matters, with particular experience in the administration of Medicare and Medicaid programs, fraud and abuse, privacy and security, and scope of practice issues. With more than a decade of healthcare legal experience based in Florida, Jamie is a valuable partner for healthcare companies doing business in or working to expand operations in the state. Read Jamie B. Gelfman'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.

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.

Abygail Hoey
Abygail Hoey is a member of the Health & Life Sciences Practice Group, where she focuses her practice on healthcare transactions, as well as regulatory and compliance matters. Read Abygail Hoey's full bio.

Breaking Down the New No Surprises Act FAQs Post-TMA III

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