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Thursday, February 11, 2021 On 28 December 2020, the federal No Surprises Act (Act) 1 was enacted. The Act seeks to protect patients from so-called “surprise medical bills” in certain emergency and nonemergency settings for out-of-network patients. This alert focuses on the Act’s arbitration provisions but first provides necessary background to those provisions. Key takeaways include: The Act, and its arbitration provisions, include both emergent and nonemergent care in certain out-of-network contexts. See Parts I and II. The Act requires payors to treat out-of-network patients as though they are in-network for purposes of: prior authorizations, coverage limits, cost sharing obligations, and out-of-pocket maximums. See Part III. ....