Skip to main content

Nixon Peabody LLP

  • People
  • Capabilities
  • Insights
  • About
Trending Topics
    • People
    • Capabilities
    • Insights
    • About
    • Locations
    • Events
    • Careers
    • Alumni
    • Contact Us
    Practices

    View All

    • Affordable Housing
    • Community Development Finance
    • Corporate & Finance
    • Cybersecurity & Privacy
    • Entertainment & Media
    • Environmental
    • Franchising & Distribution
    • Government Investigations & White Collar Defense
    • Healthcare
    • Intellectual Property
    • International Services
    • Labor, Employment, and Benefits
    • Litigation
    • Private Wealth & Advisory
    • Project Finance
    • Public Finance
    • Real Estate
    • Regulatory & Government Relations
    Industries

    View All

    • Aviation
    • Cannabis
    • Consumer
    • Energy
    • Financial Services
    • Healthcare
    • Higher Education
    • Infrastructure
    • Manufacturing
    • Nonprofit Organizations
    • Real Estate
    • Sports & Stadiums
    • Technology
    Value-Added Services

    View All

    • Alternative Fee Arrangements

      Developing innovative pricing structures and alternative fee agreement models that deliver additional value for our clients.

    • Continuing Education

      Advancing professional knowledge and offering credits for attorneys, staff and other professionals.

    • Crisis Advisory

      Helping clients respond correctly when a crisis occurs.

    • DEI Strategic Services

      Providing our clients with legal, strategic, and practical advice to make transformational changes in their organizations.

    • eDiscovery

      Leveraging law and technology to deliver sound solutions.

    • Environmental, Social, and Governance (ESG)

      We help clients create positive return on investments in people, products, and the planet.

    • Global Services

      Delivering seamless service through partnerships across the globe.

    • Innovation

      Leveraging leading-edge technology to guide change and create seamless, collaborative experiences for clients and attorneys.

    • IPED

      Industry-leading conferences focused on affordable housing, tax credits, and more.

    • Legal Project Management

      Providing actionable information to support strategic decision-making.

    • Legally Green

      Teaming with clients to advance sustainable projects, mitigate the effects of climate change, and protect our planet.

    • Nixon Peabody Trust Company

      Offering a range of investment management and fiduciary services.

    • NP Capital Connector

      Bringing together companies and investors for tomorrow’s new deals.

    • NP Second Opinion

      Offering fresh insights on cases that are delayed, over budget, or off-target from the desired resolution.

    • NP Trial

      Courtroom-ready lawyers who can resolve disputes early on clients’ terms or prevail at trial before a judge or jury.

    • Social Impact

      Creating positive impact in our communities through increasing equity, access, and opportunity.

    • Women in Dealmaking

      We provide strategic counsel on complex corporate transactions and unite dynamic women in the dealmaking arena.

    1. Home
    2. Insights
    3. Articles
    4. Developments in the No Surprises Act Independent Dispute Resolution process

      Articles

    Article

    Developments in the No Surprises Act Independent Dispute Resolution process

    Dec 17, 2025

    LinkedInX (Twitter)EmailCopy URL

    Insights on evolving No Surprises Act dispute‑resolution rules and enforcement updates impacting provider and health plan reimbursement rendered out of network.

    Authors

    • Whitney Phelps

      Partner
      • Office+1 518.427.2659
      • wphelps@nixonpeabody.com
      Whitney Phelps
    • Jonah D. Retzinger

      Partner
      • Office+1 213.629.6131
      • jretzinger@nixonpeabody.com
      Jonah D. Retzinger
    • Jennifer Greco

      Associate
      • Office+1 516.832.7641
      • jgreco@nixonpeabody.com
      Jennifer Greco
    • Freddy R. Lopez

      Associate
      • Office+1 213.629.6038
      • flopez@nixonpeabody.com
      Freddy R. Lopez
    Assistance provided by 2025 Summer Associate Gabrielle Pilla

    Nixon Peabody healthcare regulatory and reimbursement attorneys recently authored several LexisNexis Practice Guidance articles analyzing key developments in the rapidly evolving Independent Dispute Resolution (IDR) process under the No Surprises Act (NSA), which protects patients from surprise medical bills from out-of-network providers for emergency and certain nonemergency services. The publications highlight practical guides for compliance, arbitration trends, and litigation shaping how reimbursement disputes between providers and health plans are resolved.

    Across these resources, they outline:

    • Air‑ambulance‑specific IDR factors, including vehicle type, patient acuity, crew training, and pickup‑site population density
    • Enforcement challenges, including diverging federal court opinions about whether providers may seek judicial enforcement of IDR awards
    • Ongoing agency enforcement discretion through 2026 that affects Qualified Payment Amount (QPA) calculations and IDR submissions

    Read the LexisNexis Practice Guidance articles to ensure compliance and understand the latest litigation developments (subscription required).

    • Compliance for Air Ambulance Service Providers
    • Good Faith Estimates Compliance Checklist
    • Disclosure Clause for Surprise Medical Billing
    • Group Health Plan Compliance Presentation
    • Provider and Facility Compliance Presentation
    • Qualifying Payment Amounts & Median Contract Rates
    • Developments in the IDR process

    Practices

    HealthcareHealthcare Regulatory & ComplianceManaged Care Contracts & Network DevelopmentMedicare, Medicaid, and Other Government Payors

    Industries

    Healthcare

    Insights And Happenings

    • Article

      Don’t table your cap table management

      Dec 15, 2025
    • Alert

      CMS announces new value based payment model for technology-enabled care

      Dec 3, 2025
    • Article

      Preparing behavioral health organizations for sale or investment

      Oct 24, 2025
    The foregoing has been prepared for the general information of clients and friends of the firm. It is not meant to provide legal advice with respect to any specific matter and should not be acted upon without professional counsel. If you have any questions or require any further information regarding these or other related matters, please contact your regular Nixon Peabody LLP representative. This material may be considered advertising under certain rules of professional conduct.

    Subscribe to stay informed of the latest legal news, alerts, and business trends.Subscribe

    • People
    • Capabilities
    • Insights
    • About
    • Locations
    • Events
    • Careers
    • Alumni
    • Contact Us
    • Cookie Preferences
    • Privacy Policy
    • Terms of Use
    • Accessibility Statement
    • Statement of Client Rights
    • Purchase Order Terms & Conditions
    • Nixon Peabody International LLP
    • PAL
    © 2025 Nixon Peabody. All rights reserved