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.
Your PRIA Score
Personalized for You
How does this regulation affect your finances?
Sign up for a PRIA Policy Scan to see your personalized alignment score for this federal register document and every other regulation we track. We analyze your financial profile against policy provisions to show you exactly what matters to your wallet.
Key Dates
Related Federal Register Documents
2026-11140 — Federal Independent Dispute Resolution Operations
Starting soon, health plans and insurers must share clearer info when they pay or deny surprise medical bills. They’ll use special codes to explain these decisions, especially when dealing with folks they don’t have contracts with. This helps patients and providers understand bills better and speeds up fixing disputes, with no extra costs for most people.
2026-11093 — Amending the Medical Evaluation Requirements in the Respiratory Protection Standard for Certain Types of Respirators
OSHA wants to make it easier for workers using certain respirators by removing some medical check-ups for filtering facepiece and loose-fitting powered air-purifying respirators. This change affects workers who wear these masks and could save time and money on medical evaluations. The public can share their thoughts until July 6, 2026, before the rule is finalized.
2026-10849 — Labor Organization Annual Financial Reports
Starting July 1, 2026, big labor groups will fill out a longer financial report to boost transparency, while medium-sized groups get updated forms too. These changes help everyone see how union money is handled and apply only to fiscal years beginning after that date. If your labor organization handles $350,000 or more, get ready for clearer, more detailed reporting!
2026-10456 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2026
Good news for businesses and workers: the Department of Labor won’t raise any fines or penalties in 2026 because the usual inflation data wasn’t available. This means all civil penalties stay the same starting May 27, 2026. So, no surprise cost hikes this year—just steady rules and steady fees!
2026-07959 — Joint Employer Status Under the Fair Labor Standards Act, Family and Medical Leave Act, and Migrant and Seasonal Agricultural Worker Protection Act
The Department of Labor is proposing clear rules to decide when two companies share responsibility for workers’ rights under key laws like minimum wage, family leave, and farmworker protections. This change helps workers and employers understand who’s in charge and makes enforcement fair and consistent across the country. If finalized, these rules could affect many businesses and workers starting soon, with potential impacts on compliance costs and legal clarity.
2026-05492 — Retirement Security Rule: Definition of an Investment Advice Fiduciary: Notice of Court Vacatur
The court has canceled the Department of Labor’s 2024 rule that changed who counts as a trusted investment advisor for retirement plans. Starting April 20, 2026, the old rules from 2020 will be back in charge, affecting financial advisors and retirement plan managers. This means advisors should review their practices to stay on the right side of the law and avoid costly mistakes.
Previous / Next Documents
Previous: 2025-21112 — Submission for OMB Review; Comment Request
The Department of Agriculture is asking for public feedback on how it collects info for the Disaster Supplemental Nutrition Assistance Program (D-SNAP), which helps people affected by disasters get food aid quickly. They want to make sure the process is clear, useful, and not too much work for those who respond. Comments are open until December 26, 2025, so don’t miss your chance to weigh in!
Next: 2025-21114 — Agency Information Collection Activities; Submission to the Office of Management and Budget (OMB) for Review and Approval; Comment Request; Section 232 Tariff Offsets and Inclusion Processes for Automobiles and Vehicle Parts
The Department of Commerce is asking for public feedback on how it collects info about tariffs on cars and car parts, following new rules to protect U.S. security. This affects car makers, importers, and anyone dealing with these products, with comments due by January 26, 2026. The goal is to keep the process smooth and fair while making sure tariffs work as intended.