No Surprises Act Drowns in Dispute Resolution Paperwork
Published Date: 11/26/2025
Notice
Summary
The Department of Labor is asking for public feedback on a new form tied to the No Surprises Act’s independent dispute resolution (IDR) process. This process helps settle payment disagreements between health plans and out-of-network providers after negotiations fail. If you’re involved in health insurance or medical billing, this update could affect how and when payments get decided, with comments due by December 26, 2025.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 1 costs, 1 mixed.
Large private‑sector paperwork burden
The Department of Labor is collecting information tied to the No Surprises Act IDR process and estimates the affected private‑sector burden at 2,000,012 respondents, 2,755,048 responses, 1,691,251 annual hours, and $58,518,032 in annual other costs. DOL seeks OMB Paperwork Reduction Act authorization for this collection for three (3) years under OMB Control Number 1210-0169.
Limits on cost‑sharing and balance billing
The CAA/No Surprises Act added requirements that limit cost sharing, prohibit balance billing for certain items and services, and require disclosures about balance billing protections for applicable group health plans and health insurance issuers in the group and individual markets, and for air ambulance services.
Federal IDR for out‑of‑network disputes
Group health plans and health insurance issuers in the group (employer) and individual (marketplace) markets, and nonparticipating providers or facilities, may use the Federal independent dispute resolution (IDR) process after an unsuccessful open negotiation period to determine the out‑of‑network rate for certain emergency services, nonemergency items and services furnished by nonparticipating providers at participating facilities, and for air ambulance services.
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