Federal Policy
No Surprises Act Disputes Rose 16% in Second Half of 2025
Providers and payers initiated 16% more disputes under the No Surprises Act in the second half of 2025 compared to the first half, according to new CMS data released July 23, 2026. Arbiters are closing cases more quickly and working through the backlog of disputes. The No Surprises Act primarily governs commercial insurance out-of-network billing disputes and does not apply to Medicaid managed care or fee-for-service.
Why it mattersThis federal dispute resolution trend has no direct operational or compliance impact on Medicaid programs, which are exempt from No Surprises Act arbitration requirements.