The Pulse

A 22-page ruling from the U.S. District Court for the Central District of California has dismissed every claim brought against HaloMD and its co-defendants by Anthem Blue Cross of California, reaffirming that the Independent Dispute Resolution process was designed to be the final mechanism for resolving surprise billing disputes — not a launching pad for federal litigation.

Magistrate Judge Karen E. Scott rejected a grab-bag of RICO, ERISA, fraud, and state law theories that sought to collaterally attack the No Surprises Act and awards issued through Independent Dispute Resolution. The Court held that none of the claims had any legal foundation and could not be salvaged by amendment.

At the heart of the ruling is an affirmation of Congressional intent: the NSA's IDR process was designed to be final and binding, with limited avenues for judicial review. The Court characterized one of Anthem's central arguments as "a novel argument unsupported by any case law."

The federal government projected 17,000 annual IDR disputes. The system is on pace for over 2 million. Critics call this "abuse." But as HaloMD's Patrick Velliky details in a new analysis, the gap traces to a single methodological error: basing the estimate entirely on New York's IDR experience — a state whose law structurally eliminated emergency medicine disputes. The federal NSA did not. Over half of all federal disputes involve emergency medicine.

Texas offered a far more relevant model. Its law — with arbitration and no EM carve-out — generated 49,000 disputes from 5.8 million covered Texans. That same methodology would have projected over 1.5 million disputes nationally.

HaloMD spoke directly with OMB and federal agencies reviewing the IDR Operations final rule. Key priorities raised:

CARCs/RARCs: Urged immediate implementation — health plans already have access to NSA-specific codes and should not receive delayed effective dates.

IDR Registry: Supported requiring health plans to submit plan-type information, simplifying eligibility determinations and reducing administrative burden.

Cooling-Off Period: Advocated reducing the 90-day period to one business day for all disputes to prevent claims from becoming stuck in perpetual cooling-off cycles.

The No Surprises Act Enforcement Act continues to gain bipartisan momentum. Q1 2026 brought nine new cosponsors to the bill — five Republicans and four Democrats — reinforcing the broad recognition that providers need stronger tools to enforce NSA protections.

HaloMD is proud to support the work of the Dr. Lorna Breen Heroes' Foundation, an organization dedicated to improving the mental health and wellbeing of healthcare professionals. Through this partnership, HaloMD is helping advance the Foundation's ALL IN for Mental Health initiative, a national campaign focused on breaking down stigma and ensuring clinicians can access care safely and without fear of professional repercussions.

This mission is further reinforced by recent national policy progress. The Dr. Lorna Breen Health Care Provider Protection Act has been reauthorized by Congress for an additional five years, extending vital funding and programs aimed at reducing burnout and expanding access to mental health resources for healthcare workers. Together, these efforts reflect a growing commitment to supporting those who care for others.

For more information about the Dr. Lorna Breen Heroes' Foundation and the ALL IN for Mental Health program, visit www.drlornabreen.org/allinformentalhealth.

Patrick Velliky joined Becker's to discuss how providers can navigate reimbursement challenges, reduce administrative burdens, and stay independent amid payer consolidation and evolving NSA policy.

Physicians and clinicians have powerful stories to tell, and HaloMD's new Advocacy Action Center removes barriers to engagement by putting advocacy tools directly into your hands. The platform allows you to:

Send customized letters to elected officials using pre-drafted templates. Log interactions with representatives to build a documented record of engagement. Access training materials and policy resources (coming soon) to develop effective communication strategies with policymakers. Learn more about upcoming elections.

By combining critical advocacy tools with education and strategy, HaloMD creates an ecosystem where clinicians can move seamlessly from concern to action — learning about the issues, engaging in effective advocacy campaigns, and making their voices heard at critical moments in the policy process. Your representatives need to hear from you.

Staying informed is equally important to taking action. Visit the HaloMD Advocacy Action Center today to get engaged by building your advocacy record, stay informed with the latest information, and join the growing movement of healthcare providers demanding an equitable healthcare system based on clinical value.

In a landmark move, Indiana lawmakers passed legislation banning health insurers from penalizing hospitals for using out-of-network providers — a direct response to Elevance Health's controversial policy in its home state. The bill received final legislative approval on February 26 and was signed into law by Gov. Braun on March 5.

The Indiana Hospital Association, Indiana State Medical Association, and Indiana Physicians Health Alliance all backed the legislation. With Elevance controlling 68% of Indiana's commercial insurance market, advocates called the legislation critical for patient access.

The policy remains active in 10 states: Colorado, Connecticut, Georgia, Kentucky, Maine, Missouri, Nevada, New Hampshire, Ohio, and Wisconsin. California joins on June 1, 2026. Indiana is currently the only state to block it.

Despite pushback from the AHA, AMA, and 14 bipartisan House lawmakers who called for a federal investigation, Elevance has expanded the policy. After launching in 11 states on January 1, the company announced expansion to California effective June 1.

The policy reduces hospital reimbursement by up to 10% or terminates facilities from Anthem's network when hospitals refer commercial members to out-of-network providers for non-emergent care. The AHA noted that Anthem itself failed to participate in more than 30% of IDR disputes in 2024 — suggesting the insurer could address its stated concerns by improving its own operations.

The AHA's 2026 Costs of Caring report reveals hospitals spent $43 billion in administrative costs in 2025 just collecting payments from insurers. Workforce costs — roughly 60% of total expenses — rose 5.6% year-over-year. Nearly 56% of hospital costs are tied to service lines where reimbursement falls short of the cost of care.

Meanwhile, Kaufman Hall reports hospitals started 2026 with declining volumes, rising expenses, and the widest performance gap between strong and struggling hospitals in recorded history.

An estimated $911 billion in federal Medicaid spending reductions over ten years is forcing states into difficult decisions. States including Idaho, North Carolina, and Colorado have announced provider rate cuts of 3–10%. Work requirements begin by end of 2026, and the CBO estimates approximately 10 million people could become uninsured.

After years of backlogs, the federal IDR system has reached a critical milestone. Certified IDR entities closed over 257,000 disputes in January 2026, effectively matching the pace of new filings — a clear signal the system is functioning at scale.

Meanwhile, a Congressional Research Service report confirms providers prevailed in 83–88% of payment determinations in 2024.

A new investigation by journalist and former health insurance executive Wendell Potter documents a coordinated wave of federal lawsuits filed by major health insurers over the past year — targeting providers and revenue cycle firms that have used the No Surprises Act's Independent Dispute Resolution process. Potter notes that the suits, filed across multiple jurisdictions, rely on nearly identical language and legal theories.

Potter's central question: with the majority of submitted disputes found eligible by independent arbitrators and providers prevailing in roughly 85% of determinations, is this litigation about rule-breaking — or about discouraging providers from using the legal process Congress designed for them?

What it is: CMS announced the IDR Gateway — a centralized platform that will replace the current system of single-use web forms for managing federal IDR disputes under the No Surprises Act. The transition is expected in the second half of 2026.

What it does: The Gateway consolidates dispute initiation, response, tracking, and reporting into a single portal. Organizations will have access to dashboards, phase-level dispute monitoring, and activity notifications. CMS is also introducing new security protocols, including identity verification and U.S.-based access requirements.

What it means for providers: This is a significant infrastructure shift for any organization managing IDR volume. The transition will require re-registration, adaptation to new workflows, and alignment with updated submission processes — all while the IDR Operations Final Rule remains pending, which could introduce additional procedural changes. How the Gateway and the Final Rule interact operationally is still an open question.

Payers must now provide prior authorization decisions within 72 hours for urgent requests and seven calendar days for standard requests under CMS's Interoperability and Prior Authorization Final Rule (CMS-0057-F). Denials must include specific reasons, and payers will publicly report authorization metrics. Meanwhile, major health plans serving 270 million Americans have begun voluntary commitments through AHIP, and the AMA's Improving Seniors' Timely Access to Care Act now has 248 House and 64 Senate co-sponsors.

Elevance California rollout (June 1). The penalty policy hits the nation's largest state. Watch for legislative response — California has historically been aggressive on provider protections.

IDR Operations Final Rule. After HaloMD's OMB engagement and years of stakeholder input, the finalized rule could reshape eligibility determinations, cooling-off periods, and portal operations. Timing remains uncertain but expected in 2026.

IDR Gateway launch (H2 2026). CMS's centralized platform will replace the existing web forms. Providers should prepare for new registration and identity verification requirements.

Medicaid work requirements (late 2026). As states implement eligibility changes, provider organizations should model the impact on payer mix and uncompensated care projections.

Prior authorization enforcement. The CMS rule's new timelines are now in effect. Q2 data will show whether payers are meeting the 72-hour and 7-day standards — or whether enforcement gaps persist.