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Transparency/Surprise Billing Resource Center
Nothing written by SPBA is legal advice.
Independent Dispute Resolution
No Surprises Act Regulations Part II - Independent Dispute Resolution (Webinar)
(10/13/21)
Articles and Materials
SPBA Spring Meeting Presentation Addresses Challenges and Some Solutions to the IDR Process
(6/24/25)
IRS Releases Guidance on Calculating 2024 QPA Payments
(3/21/24)
No Surprises Act Independent Dispute Resolution Process Proposed Rule
(12/15/23)
Calculating the QPA in the Aftermath of the Texas Medical Association et al. Case
(10/31/23)
Overview Highlights of the SPBA Spring Meeting Session: “The No Surprises Act Independent Dispute Resolution Process”
(5/1/23)
Independent Dispute Resolution: Status Update
(3/10/23)
H. The No Surprises Act Independent Dispute Resolution Process from the Date of Service to the Decision of the IDR Entity - Scott Bennett
(3/28/22)
Federal IDR Portal Stakeholder Testing Round Table
(2/25/22)
Federal Judge Strikes Down Pieces of No Surprises Act Independent Dispute Resolution IFR
(2/24/22)
SPBA Submits Comment Letter on No Surprises Act Independent Dispute Resolution Process
(12/15/21)
No Surprises Act and Transparency Effective Date Chart
(10/19/21)
No Surprises Act Regulations - Part II Released
(10/4/21)
Official Source Documents
Fact Sheet: No Surprises Act Independent Dispute Resolution Process Proposed Rule
(11/3/23)
ACA FAQ Part 62 on QPA Post Court Decision in TMA III
(10/20/23)
Payment Disputes Between Providers and Health Plans
(9/19/23)
IDR Disputing Parties Guidance for payment determinations made on or after February 6, 2023 for items and services furnished on or after October 25, 2022 for plan years beginning on or after January 1, 2022
(4/24/23)
Guidance for IDR Entities for payment determinations made on or after February 6, 2023 for items and services furnished on or after October 25, 2022 for plan years beginning on or after January 1, 2022
(4/24/23)
Webinar
Webinar: New Proposed Federal IDR Process, Court Decision, New FAQ and AI Compliance Tools
(12/5/23)
Plan Transparency
Articles and Materials
Transparency in Coverage Machine-readable Files FAQ Part 70
(6/11/25)
Enforcement Relief for Gag Clause Prohibition Compliance Attestation
(4/30/25)
Departments Issue FAQ 69 on Independent Dispute Resolution and the Gag Clause
(2/25/25)
CAA HB SB Gag Clause Chart
(8/29/24)
Gag Clause Prohibition Compliance Attestation User Manual Updated
(6/28/24)
Machine‑Readable Rx Files Enforcement
(10/26/23)
TinC 2.0 Complexity and HR 3561 Impact
(7/14/23)
New Requirements Under CMS' Transparency in Coverage Rule Take Effect January 1, 2024
(6/30/23)
The CAA Gag Clause Prohibition Attestation
(6/29/23)
New Requirements Under CMS' Transparency in Coverage Rule Take Effect January 1, 2024
(6/26/23)
Transparency in Coverage Rules….What is it and What it Requires Part 1
(7/15/21)
Future Rollout of Federal Guidance Planned
(7/7/21)
SPBA Transparency Summit - 3rd Session - Video Recording
(6/15/21)
SPBA Transparency Summit - 2nd Session - Video Recording
(3/29/21)
SPBA Transparency Summit - 1st Session - Video Recording
(3/22/21)
SPBA Transparency Summit Slides - March 18, 2021
(3/18/21)
Administration Finalizes Transparency in Coverage Rule
(11/24/20)
SPBA Comments on CMS Transparency in Coverage Proposed Rule
(2/6/20)
SPBA's Comments on Transparency Submitted to HHS
(6/28/18)
Media Reports on Medical $ Transparency
(4/9/13)
Escape the Fire (Health Care) Trailer
(3/28/13)
Sales Tool & Opportunity
(2/9/12)
Official Source Documents
Gag Clause Prohibition Compliance Attestation Annual Submission Instructions & User Manual 2024
(6/5/24)
Transparency in Coverage Final Rule
(8/6/21)
Health Coverage Transparency Proposed Rule 11-2019
(11/22/19)
HHS Report on Reforming America's Healthcare System Through Choice & Competition
(8/1/19)
Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First
(6/25/19)
Surprise Billing
No Surprises Act - First Set of New Regulations (Webinar)
(7/20/21)
Articles and Materials
Progress Toward Advanced Explanation of Benefits (AEOB) Rulemaking and Implementation
(12/16/24)
No Surprises Act – Determining Cost-Sharing and Payment Amounts to Providers
(12/13/24)
National Emergency or Public Health Emergency Declaration
(9/2/22)
SPBA Reviews the Administration's Executive Order
(7/15/21)
Future Rollout of Federal Guidance Planned
(7/7/21)
Administration Releases Interim Final Rule on the No Surprises Act
(7/2/21)
Advanced Explanation of Benefits in the No Surprises Act
(5/28/21)
SPBA Submits Comments on No Surprises Act Regulations
(5/26/21)
F. New Federal No Surprises Act & Related Transparency Requirements
(4/7/21)
End of Year Spending and COVID Stimulus Package: A Summary
(2/4/21)
No Surprises Act - Section by Section Summary
(2/4/21)
Official Source Documents
HHS Progress-AEOB-Rulemaking-Implementation-1 April 2024
(12/16/24)
HHS Progress on AEOB Rulemaking Update-2 December-2024
(12/16/24)
Interim Final Rule - Requirements Related to Surprise Billing Part II
(4/24/23)
Guidance for IDR Entities for payment determinations made on or after February 6, 2023 for items and services furnished on or after October 25, 2022 for plan years beginning on or after January 1, 2022
(4/24/23)
Requirements Related to Surprise Billing - Final Rules (8/2022)
(4/24/23)
Rx Reporting IFR
(8/15/22)
Surprise Billing Model Notice
(10/18/21)
Interim Final Rule - Requirements Related to Surprise Billing; Part I
(8/6/21)
No Surprises Act Bill Text
(2/4/21)
Hospital Transparency
Articles and Materials
SPBA Meeting with GAO on the Use of Hospital Pricing Information
(2/27/24)
SPBA Comments on CMS Hospital Transparency Proposed Rule
(2/6/20)
YOUR Achievement on Hospital Price Transparency
(5/8/13)
Transparency Documentary Trailer
(6/5/12)
SPBA Policy Brief on Hospital Transparency (Updated version posted 4/20/12)
(10/28/11)
Sharing Hospital Transparency
(7/12/11)
Hospital Transparency
(6/3/11)
Reference-Based Pricing
Articles and Materials
How Montana cut healthcare costs with reference-based pricing
(1/3/19)
Webinar
Webinar: Reference-Based Pricing
(1/3/19)