A running reference for the No Surprises Act as it actually plays out — regulatory guidance, litigation, arbitration data, and market shifts, tracked as they happen.
Dispute volume per CMS Federal IDR bi-monthly report (as of May 31, 2026) — see the IDR Statistics page for the full trend. Median award figure per Jack Hoadley & Kennah Watts, Georgetown CHIR/Health Affairs Forefront analysis of CMS Federal IDR Public Use Files (Aug. 2026).
A running log of regulatory, legal, and market developments.
Energy and Commerce Committee Ranking Member Frank Pallone (D-NJ) sent oversight letters to six certified IDR entities — C2C Innovative Solutions, Commence, Dane Street, EdiPhy Advisors, National Medical Reviews, and ProPeer Resources — questioning whether arbitration is "functioning as Congress intended." Pallone cited winning offers that "far exceed commercial payment rates" and pointed to rising premiums, while also flagging IDR entities' lack of responsiveness to prior document requests. Separately, the bipartisan No Surprises Act Enforcement Act (H.R. 4710) remains pending before three House committees — Ways and Means, Education and Workforce, and Energy and Commerce — more than a year after introduction, with Ways and Means continuing its multi-year pattern of NSA implementation oversight. Together, these signal that Congress is actively weighing both stronger enforcement of IDR outcomes and closer scrutiny of the arbitrators making them.
A Health Affairs Forefront analysis from Georgetown's Center on Health Insurance Reforms (Jack Hoadley & Kennah Watts) estimates the federal IDR process generated $22.4 billion in total costs from 2022 through 2025 — $15.6 billion in payment awards above the QPA, $4.2 billion in estimated internal administrative costs, and $2.7 billion in IDR fees. 2025 alone accounted for $16.6 billion, roughly 3.5x the 2024 total, driven by dispute volume up 77% year-over-year and total award dollars up 264%. Providers continue to win about 85% of disputes, with a median 2025 award of 445% of QPA (up slightly from 447% in 2024, but with a much fatter tail: the 90th percentile jumped from 1,226% of QPA in 2024 to 1,771% in 2025). The piece names Radiology Partners, HaloMD, and TeamHealth as filing over three-quarters of resolved dispute lines in 2025, and reports early signs of IDR costs feeding into premiums — including one state employee plan citing IDR as a primary driver of a nearly 10% rate increase. See our IDR Statistics page for the detailed cost and award breakdowns.
A National Bureau of Economic Research working paper (Barwick, Li, Xia & Yu, “The No Surprises Act's Surprises,” NBER WP 35717, Sept. 2026) links federal IDR records to a national provider-network panel and ACA marketplace plan data. The authors find in-network participation fell after the NSA in the specialties and states most exposed to it — emergency medicine, anesthesiology, and radiology — the opposite of what a simple balance-billing-ban story would predict. They trace this to IDR itself: providers won about 86% of resolved disputes, with prevailing offers averaging roughly 10x the QPA, and network exit accelerated after a provider group's first favorable arbitration outcome. The paper also reports suggestive evidence that insurers more exposed to arbitration raised premiums faster. Worth a careful read for anyone pricing or reserving around IDR-driven cost volatility.
Before the No Surprises Act, an out-of-network bill for emergency or ancillary care often landed on the patient. Now the provider and the payer settle it directly — through negotiation or, failing that, a federal arbitration process. That shift didn't remove the cost from the system. It moved the dispute upstream, into claims administration, stop-loss contracts, captive reserves, and plan sponsor budgets — and it keeps evolving as courts and regulators weigh in. This site tracks that evolution and defines the terms as they come up.