After commenting multiple times, 100s of hours of work and waiting nearly 2.5 years, our considerable advocacy as a community has paid off—here are the highlights from the CMS Final Rule on IDR Operations under the #NoSurprisesAct —my editorial comments in are in bold:
1. Plans and issuers must use CARCs and RARCs to communicate NSA-related information on remittance advice. Huge potential win for physicians and will reduce the ineligible claims significantly.
2. Open negotiation must move through the Federal IDR portal, with expanded notice content. The plans have been ignoring the open negotiation (ON) process—not sure that will be working so well for them now.
3. A new open negotiation response notice is required within the first 15 business days. See previous comments.
4. IDR initiation notices require more information, and the non-initiating party must respond within 3 business days. Potentially neutral.
5. Certified IDR entities get 5 business days after final selection to make eligibility determinations. Also potentially good when the CARCs and RARCs are mandated.
6. Plans and issuers must register in the Federal IDR portal. This could be huge but the devil will be in the details.
7. Batching rules are expanded and clarified. Could be a plus/minus
8. Cooling-off for batched disputes is reduced to 30 business days. Better, but we wanted 1 day cooling but way better than the current 90 days.
9. The administrative fee is reduced to $15 per party per dispute. Huge win here as the current CMS fee is $115 per party.
10. CMS declines to finalize certain proposed fee-collection changes and reduced-fee structures for low-dollar or ineligible disputes. The low dollar structure could have really helped radiology.
For those who question the resources spent in time and money for advocacy by the physician and supporting community, this rule, subject to reviewing all 600+ pages, could be Exhibit A for why we do it.
https://t.co/BCQYKbyPnk
1/ Unfortunately Becker’s buried the lead here.
Yes @UHC is seeking a premium increase by 10/1/26 in #MD—OF OVER 17%!!!
Recall that 2025 was the worst $ year for UHC of the last 10. In the spring of ‘25, after denying the @WSJ stories for months, UHC finally admitted to both civil and criminal investigations of their #MedicareAdvantage (MA) lines of business. CEO abruptly resigned his position and then from the board, with United announcing “an internal investigation” of its MA biz.
So, is United expecting the good folks of Maryland and other states to pay for their poor management? Sure sounds like that is occurring. Are major increases in the cards for the rest of America?
26,000 Maryland UnitedHealth members could see mid-year rate increases https://t.co/yt4B5HLxpI
Exhibit A for passage of the No Surprises Act Enforcement Act (H.R. 4710) is demonstrated by the experience of Radiology Associates of North Texas (RANT), one of the largest independent radiology groups in the US.
According to Radiology Business (5/20/2026), "Radiology Associates estimates it has prevailed in about 95% of finalized IDR disputes with Blue Cross Blue Shield of Texas, the state’s largest insurer. However, more than $3.5 million in awarded balances remain unpaid. RANT estimated that $1.64 million of this total has been outstanding for over 120 days. As of Tuesday, BCBS Texas has paid approximately 2% of awarded balances."
RANT is not alone in this experience.
The Emergency Dept. Practice Management Association (EDPMA), representing well over 60% of the ED groups providing care to ED patients (or organizations supporting the provision of care), released a study in April 2026 of over 659,000 successful NSA IDR claims won by its members in 2025. Yet, 48% of those IDR determinations were not paid within the 30-day period required by law. The total outstanding of award determinations not paid by the health plans exceeded $245,000,000.
Congress must pass HR 4710 to give CMS the same enforcement authority it has over hospitals and physicians that it does not currently have over health plans, mainly the ability to assess Civil Monetary Penalties (CMPs) for non-compliance with the NSA.
Radiology Associates of North Texas says it will waste over $51M on costs related to No Surprises Act https://t.co/VipNBtfaaG
@e_considine@TomOliverson I'm not quite sure I've ever had a plumber give me a preset price. It's always this is the cost of just figuring out what the problem might be.
And physcians who are not employed by a Healthcare system or Insurance entity don't have a preset salary. They have an office to run.
To be fair, Medicare grossly underpays doctors while paying hospitals close to market rates. So while 300% Medicare charged by a hospital is unacceptable, it’s not the case for physicians. If you don’t believe me, just compare reimbursement rate increases over the last 40 yrs by Medicare for docs vs. hospitals.
@e_considine@TomOliverson Not sure about that. My plumber charges more per hour than most physicians. On top of the fact that physician's don't start earning significant income till there mid 30s after incurring over a quarter million dollars worth of debt.
@yn3590570219192 I don't think you're ever going to solve the problem of underserved areas by having people permanently relocate there. Economics make that cost prohibitive. But if you have a steady stream of physicians going through for two years at a time, it will still provide better access
HB2038, a bill passed unanimously by all Republicans in the legislature and now being implemented by the TMB had its strongest advocates with conservative think tanks who were forward thinking on how to tackle physcian shortages.
https://t.co/PJJ4EaRUL8
@AkaLazarus@EduMontesin@AJCGlobal The Islamic Society of North America (ISNA) has historically extended greetings for Passover, acknowledging the holiday as part of a season of shared spring celebrations among diverse faiths. These gestures emphasize community dialogue, mutual respect, and shared traditions.
@sabarizvimd Saba, great question. There are countries who are certified by ACGME International who determine equivalence. Those who don't will have to go through a KStar assessment to be able to move on to provisional licensure. Those will be specialty specific.
@DrAlexUrology@nanalambchop This is not about a competition. There is only a finite number of GME spots. TX is the 19th state to institute a process where someone who did GME outside of the US can go through a provisional license process without repeating residency. Part of it is rural practice for 2 years.
@nanalambchop The commitment and the charge from the legislature is to make sure that they are all properly vetted through a series of provisional licenses in a controlled setting before they can get an unrestricted license.
One of the major problems with Medicare is that prices are set by a political process, not a market process.
And hospitals have a lot of political power.
#PatientSafety is a team sport! Over the past weekend I represented @ASALifeline at the @APSForg Board meeting, along with ASA members including @TSAPhysicians President @ERebelloMD, APSF board member @szaafran, and ASA Past President and current APSF President Dr. Dan Cole.
🪡 🧵I appreciate @EdGainesIII bringing up the healthplans priorities & refuting them. I will expand on his discussion.
1/ AHIP claims it wants to “make health care more affordable.” https://t.co/bLX5pD5eXk
As a solo independent physician who deals daily with the No Surprises Act (NSA) and IDR, here’s a fact-based, point-by-point response using backing claims— not talking points.
AHIP’s July 30, 2025 article claims Congress should “Stop Private Equity’s Misuse of the No Surprises Act (NSA).” I’m a solo independent physician who works daily inside NSA Independent Dispute Resolution (IDR), and the real problem is health plans’ “No / Low / Slow Pay” after they LOSE binding arbitration, combined with procedural gamesmanship that forces small practices like mine to keep writing obscene checks just to get paid fairly.
CMS reports that as of Nov. 30, 2025, 4,634,956 IDR disputes had been initiated and over 3.2 million payment determinations issued.
https://t.co/814iOtB6wh
Congressional Research Service reports ~$718 million in IDR fees in 2024 alone, with initiating parties’ offers selected ~85% of the time, which directly contradicts the claim that physicians are abusing arbitration.
https://t.co/NNFDWNlKfb
The AMA documents that late payment & nonpayment after IDR determinations is widespread, despite the statute requiring timely payment.
https://t.co/2Pd8SZOU6z
Mixed court decisions on enforcement of NSA IDR determinations is a Red Line that Congress needs to Act to eliminate judicial ambiguity.
https://t.co/KFAvkRog5E
https://t.co/723bzhekEQ
Congress already wrote the rule. Now enforce it. Sign on and Vote Yes on
No Surprises Act Enforcement Act (Murphy–Marshall):
House: https://t.co/pByBwssobM
Senate: https://t.co/na3aEPgU93
https://t.co/bLX5pD5eXk
@RobertKennedyJr@DrOz@realDonaldTrump@MikeJohnson@LeaderJohnThune@RepRaulRuizMD@DrKimSchrier@RepHerbConaway@herbconaway @MaxineDexterMD @Morrison4MN@RepBera@RepMMM@RepMarkGreen@RepGregMurphy@RepRonnyJackson@RepJohnJoyce@RepNealDunn@RepAndyHarrisMD@RichforGA @RepDesJarlais @SenJohnBarrasso@SenBillCassidy@RogerMarshallMD@DrRandPaul @MikeKennedyUT @BobOnderMO@RepRaulRuizMD@DrKimSchrier@RepHerbConaway
@MaxineDexterMD @Morrison4MN@RepBera@GOPDoctors
@DrBruggeman@CRCook1978 We should ask insurers owned physcian practices if they pay them what they claim is the QPA? Will they commit to paying them that same rate? I'll wait for a non answer from them. United bragged that they pay their Optum owned physicians a higher rate.