Recent weeks have seen several developments and new information in the use of the No Surprises Act’s independent dispute resolution process for health care billing disputes between payers and providers over out-of-network care.

The number of disputes directed to independent dispute resolution continues to rise – 16 percent more during the second half of 2025 than during the first half of that year.  Providers continue to initiate about three-quarters of the disputes and to win about 85 percent of those cases.  Most of the provider-driven disputes are intiated by small provider groups, many of them represented by just a few companies that handle their disputes for them.  Learn more about the continued increase in the number of disputes submitted to arbitration from the Healthcare Dive article “No Surprises disputes continue to swell, CMS finds.”

Perhaps unsurprising in light of the increase in the number of cases going to arbitration, the amount of money awarded in those cases continues to rise – to close to $15 billion in 2025, according to the Wall Street Journal, three times as much as the nearly $5 billion awarded in 2024.  Learn more from the Journal article “Medical Billing Arbitration Paid Out $15 Billion to Providers in Surprise Bill Disputes” (subscription required, or see the Becker’s Hospital Review story “No Surprises arbitration payouts hit $15B in 2025 alone: WSJ.”

Meanwhile, this week the Centers for Medicare & Medicaid Services published guidance on required remittance advice remark codes, or RARCs, and claim adjustment reason codes, or CARCs, that insurers must use in the No Surprises Act’s independent dispute resolution process for out-of-network claims; CARCs explain why a claim or service line was paid differently from how it was billed and RARCs provide additional explanation for the remittance.  The guidance applies to out-of-network services and items provided on or after January 1, 2027.  Learn more about the RARCs and CARCs and their intended use in the No Surprises Act’s independent dispute resolution process from this CMS announcement and this CMS guidance.

Finally, CMS continues to tease the introduction of a new electronic mechanism for managing disputes between payers and providers.  “The IDR Gateway Is Coming Soon!,” the agency writes, adding that “In late 2026, the Federal Independent Dispute Resolution (IDR) process will transition from single-use web forms to the new IDR Gateway, which will provide a secure, centralized platform that parties can use to manage disputes. See this notice and a more detailed description of how the new gateway will work and what it will do from this CMS notice.