December 21, 2020 – Omnibus Spending Bill Provisions

This Steptoe & Johnson legal memo provides The Council's initial analysis of the No Surprises Act and healthcare transparency provisions in the December 2020 Omnibus spending bill. Key provisions include a surprise medical billing framework establishing qualifying payment amounts (median contracted rates) as the benchmark for out-of-network payment disputes, and a new broker compensation disclosure requirement mandating upfront disclosure of all direct and indirect compensation from employer health plans. The memo explains implications for brokers, payors, and plan sponsors.