No Surprises Act Implementation: Immediate Challenges for Payers and Providers

The federal No Surprises Act (NSA), which went into effect January 1, 2022, protects patients from surprise medical bills for emergency services and for when they are treated by out-of-network providers in an in-network facility in certain circumstances. The NSA also sets a methodology that will be used to determine out-of-network enrollee cost sharing and provider reimbursement in those situations—at least when state law does not determine those amounts.

Because most states already have some form of patient protections for surprise medical bills, the NSA creates a complex landscape of state and federal law interactions. As we move forward with implementation, fully understanding state and federal guidance—and the interactions between them—will be imperative for ensuring that providers’ billing practices and plans’ processing practices are compliant. In a new CLE-eligible webinar, Manatt provides guidance on successfully navigating the complexities and challenges that the NSA introduces. Key topics include:

  • Consequences of ongoing litigation on the federal independent dispute resolution process for payer-provider reimbursement disputes
  • State and federal enforcement approaches and priorities
  • Key operational implementation challenges for payers and providers
  • Recent and upcoming regulatory guidance


Michael Kolber, Partner, Manatt Health
Harvey Rochman, Partner, Manatt Health
Steve Chiu, Partner, Manatt Health

Date and Time:

Wednesday, March 30
1:00 – 2:00 p.m. ET


This program has been approved for 1.0 NY CLE Professional Practice (transitional and non-transitional) and for 1.0 CA MCLE General credit.

If you would like to receive an audio transcript of this webinar due to accessibility issues, please email us at

This program does not constitute legal advice, nor does it establish an attorney-client relationship. Views expressed by presenters are strictly their own and should not be construed to be the views of Manatt or attributed to Manatt.



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