No Surprises Act Significantly Reduces Out-Of-Network Emergency Costs by Up to 52%

Major Reduction in Emergency Medical Costs

A recent analysis by HaloMD has unveiled a significant shift in out-of-network (OON) emergency medical spending, revealing a reduction ranging from 13% to an astonishing 52% following the implementation of the No Surprises Act (NSA) in January 2022. This groundbreaking finding indicates not only a substantial impact on individual patients but also a significant drop in overall medical costs attributed to emergency medicine.

The Financial Implications

According to the analysis, even using the most conservative model, OON spending is estimated to be nearly $1 billion lower than it would have been prior to the enactment of the NSA. The research draws from a wealth of publicly available data, including the Brookings Institution's NSA Arbitration Databook, CMS IDR Public Use Files, and surveys conducted by major organizations like AHIP and the Blue Cross Blue Shield Association. This comprehensive data collection has helped establish a baseline for OON emergency claims prior to the NSA, which averaged around $641.71 per claim.

Key Savings Identified

One of the standout findings of the analysis showcased that the NSA potentially saves the healthcare system between $978 million to $3.95 billion annually when applied to approximately 11.9 million OON emergency medicine claims affected by the NSA. Notably, around 76% of claims eligible for arbitration were resolved through initial insurer payments rather than through formal arbitration processes. In fact, only about 9.5% of OON emergency medicine claims proceeded to arbitration in 2025, underlining the efficacy of negotiations prior to litigation.

Understanding the Data

The average cost award for arbitration in 2025 stood at approximately $630 per claim, which closely mirrors the pre-NSA baseline. This signifies the effectiveness of the NSA in ensuring that emergency medical services are more financially accessible to patients, highlighting the act's role not just as a consumer protection measure but also as a mechanism to lower costs across the board.

Why These Findings Matter

The No Surprises Act was primarily designed to eliminate unexpected out-of-network bills that can be a financial crisis for patients. However, it evidently also serves a crucial secondary function in reducing overall medical spending. Patrick Velliky, HaloMD's Chief External Affairs Officer, emphasized this dual impact, stating, "The NSA has successfully protected patients, but this analysis shows it has also served a secondary goal of lowering medical costs."

Examining the broader implications of these findings, Alla LaRoque, President and CEO of HaloMD, pointed out the importance of understanding the complete OON payment system. "When considering the entire out-of-network payment landscape, arbitration is a minor aspect of the overall picture. Patients currently face lower costs for emergency care due to the No Surprises Act."

Implications for Policy Making

These interesting findings hold critical weight in ongoing policy discussions related to the NSA. Much of the existing literature has emphasized IDR awards while neglecting the larger volume of claims that are resolved through initial payments and negotiations. As Congress aims to further refine the NSA's implementation, this analysis provides a robust, data-driven framework to assess the true impact of the legislation on the healthcare system.

The Methodology Behind the Analysis

The study established a pre-NSA OON baseline using historical data on allowed amounts for emergency medicine as researched by the Brookings Institution. It modeled post-NSA spending based on two pathways: claims resolved after initial payments or open negotiations, and those resolved via the IDR process. Given the lack of public payment data for claims subject to the NSA and eligible for the IDR process that are resolved outside of it, several scenarios were examined to evaluate the potential results on annual savings.

About HaloMD

Established as a premier provider of Independent Dispute Resolution (IDR) services, HaloMD is dedicated to simplifying the healthcare reimbursement process via advanced technology and analytics. Serving over 25,000 healthcare professionals nationwide, HaloMD plays an essential role in navigating the complexities of the NSA and balancing billing laws to ensure high-quality patient care.