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Article · Compliance

No Surprises Act: 2026 enforcement update for U.S. providers

The 2026 enforcement changes, the open questions on IDR arbitration timing, and what changed in good-faith estimate requirements that practices need to update this quarter.

  • MCMark Chen, JD · Reviewed by Dr. Priya Shah, MD
  • 7 min read
  • Published April 8, 2026

The lede

The No Surprises Act enforcement landscape shifted again in early 2026. If your good-faith estimate workflow has not been updated since Q4 2025, it is likely out of compliance.

This update covers the federal enforcement priorities for the coming year, the open questions on IDR arbitration timing, and the operational gaps practices most often miss.

What this piece covers

  • 2026 enforcement priorities and likely audit triggers.
  • Updates to good-faith estimate disclosures.
  • IDR timing and the rolling backlog at the federal portal.
  • A two-week checklist to bring your workflow current.

In editorial review

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