White paper · 2026-01-22Overview
The No Surprises Act, in effect since January 2022, has reshaped billing operations for hospital-based specialties (emergency medicine, anesthesiology, radiology, pathology). This two-year retrospective covers ~2.1M IDR-eligible claims across the Medonix cohort, January 2024 through December 2025.
The IDR arbitration outcomes have stabilized after the rocky 2022-2023 period: provider win rate sits at 71% across the cohort, up from 53% in early 2023 as both providers and payers internalized the qualifying-payment-amount methodology and the IDR entity decisioning patterns.
Patient billing-complaint rates have dropped 64% from pre-NSA baseline. The law is achieving its consumer-facing intent. The operational cost story is murkier: cohort-average compliance cost per ED claim sits at $7.40 incremental, mostly absorbed in patient-communication and IDR-administration overhead.
Key findings
- ✓Provider win rate at IDR arbitration: 71% (up from 53% in early 2023).
- ✓Median time to IDR resolution: 47 days (down from 89 days in 2023).
- ✓Patient billing-complaint rate down 64% from pre-NSA baseline.
- ✓Cohort-average compliance cost: $7.40 incremental per ED claim.
- ✓Open enforcement question: NSA application to ground ambulance, pending federal guidance.
What is in the report
- IDR arbitration win rates by specialty
- Median time to IDR resolution
- Patient billing-complaint rates pre / post NSA
- Operational cost of compliance per practice
- Open enforcement questions going into 2026
Methodology
~2.1M IDR-eligible claim records across the Medonix cohort, January 1, 2024 through December 31, 2025. IDR outcomes drawn from CMS public datasets cross-referenced to cohort-claim records. Compliance cost calculated using cohort-reported labor + technology overhead.
Citation: Medonix Research, "No Surprises Act: Two-Year Impact Study (2024–2026)," 2026.