Strengthening the NSA’s Independent Dispute Resolution Process: Stakeholder Perspectives

The No Surprises Act (NSA), enacted in 2020, protects patients from surprise medical bills for emergency services and, in certain circumstances, when treated by out-of-network providers in an in-network facility. Since the law went into effect at the beginning of 2022, policy and operational issues have emerged in the implementation of the statutorily prescribed independent dispute resolution (IDR) process for settling out-of-network provider reimbursement disputes. Public comment recently closed on a proposed rule that seeks to address these challenges, but there clearly is still significant room for improvement.

In a new report and webinar, Manatt Health shares several key recommendations for strengthening the open negotiation and the IDR process, based on interviews with regulators, providers, payers, experts and independent dispute resolution entities (IDREs). Key topics include:

  • A detailed background on the NSA IDR process
  • An overview of key reforms in the proposed rule
  • Recommendations from a broad range of stakeholders for improving critical elements of the IDR process, including:
    • Eligibility determinations
    • Dispute initiation and adjudication
    • The IDR portal
  • A look ahead at what’s next—and how to prepare your organization


Date and Time:

Thursday, January 18
1:00 – 2:00 p.m. ET

If you would like to receive an audio transcript of this webinar due to accessibility issues, please email us at

This program does not constitute legal advice, nor does it establish an attorney-client relationship. Views expressed by presenters are strictly their own and should not be construed to be the views of Manatt or attributed to Manatt.



pursuant to New York DR 2-101(f)

© 2024 Manatt, Phelps & Phillips, LLP.

All rights reserved