CMS provides guidance on No Surprises Act dispute resolution process

August 11, 2022

The Centers for Medicare and Medicaid Services has posted guidance and checklist regarding the independent dispute resolution (IDS) process for out-of-network claims under the No Surprises Act (NSA). The federal IDS process and panel of arbitrators applies to out-of-network emergency services and for out-of-network services provided at an in-network facility for enrollees where the state’s Balance Billing Protection Act (BBPA) process does not apply.  The state’s BBPA dispute resolution process applies to payments for enrollees of state-regulated insurance, self-funded groups that have opted into the BBPA, and for emergency and crisis behavioral health services.  More information regarding the distinction between BBPA and NSA processes with links to additional resources are in our recent bulletin. (Andrew Busz,


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