• Health Care Client Update: No Surprises Act

    On January 1, 2022, two Interim Final Rules (the “Rules”) that implement key aspects of the No Surprises Act (“NSA”) became effective. The first Interim Final Rule was initially issued by the U.S. Departments of Health and Human Services (“HHS”), Labor, and Treasury, and the Office of Personnel Management (collectively, the “Departments”) on July 1, 2021. The second, issued by the same agencies, was issued on October 7, 2021. Generally, the NSA, which was signed into law on December 27, 2020, (1) limits cost-sharing and prohibits balance billing in certain situations and (2) requires providers to provide good faith estimates (“GFE”) of charges to uninsured or self-pay patients. The NSA and the Rules also establish notice and consent requirements and dispute resolution processes in both instances.

  • 12.2021

    As outlined in our earlier alert, there is now a vaccine requirement for foreign nationals seeking nonimmigrant entry to the United States after international air travel.  

  • 10.2021

    The long awaited Presidential Proclamation rescinding the current COVID-19 travel bans was issued on October 25, 2021. The proclamation becomes effective on November 8, 2021 at 12:01 am EST and replaces the existing bans with a vaccination requirement for foreign nationals seeking nonimmigrant entry to the United States after international air travel. In addition, three Centers for Disease Control and Prevention (CDC) Orders on vaccination, testing, and contact tracing were issued as well as technical instructions to provide implementation details to the airlines and their passengers. Below is an overview of these orders and the technical instructions for implementation.

  • 09.2021

    Overview: On September 9, 2021, the Biden Administration issued a variety of measures designed to promote COVID-19 safeguards and decrease the spread of the COVID-19 virus. Such measures included two Executive Orders and President Biden’s COVID-19 Action Plan, all three of which greatly impact employers of varying sizes and industries. The Plan and each Executive Order are discussed in more detail below.

  • 07.2021

    On July 6, 2021, the Department of State (DOS) issued guidance stating that national interest exceptions (NIEs) issued in the last 12 months are being automatically extended for 12 months from the date of approval, and for multiple entries, as long as they are used for the purpose under which they were granted. The extension applies to NIEs for travelers subject to Presidential Proclamations 9984 (China), 9992 (Iran), 10143 (Schengen Area, U.K., Ireland, Brazil, and South Africa), and 10199 (India). The official guidance from DOS can be found here. More information on the Geographic COVID-19 Related Travel Bans can be found here

  • 04.2021

    When state and local governments began issuing shutdown and stay-at-home orders a little over a year ago, it was difficult to fathom how long businesses would be struggling to operate within the boundaries of the unprecedented restrictions. The economy has been hit hard across the board, with the U.S. travel and hospitality industry suffering an estimated $1.1 trillion in direct and indirect losses in 2020, hospitals and healthcare systems losing at least $323 billion in 2020, the NCAA and the four major U.S. sports leagues losing at least $14.1 billion, many major retailers declaring bankruptcy, and millions of small businesses expecting to fold in 2021 under the pressure of sustained business losses.

  • 03.2021
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