New Analysis: No Surprises Act Cuts Out-Of-Network Emergency Spending by as Much as 52%

Most Conservative Model Estimates Nearly $1 Billion in Annual Savings as Only 9% of Eligible Emergency Medicine Claims Reach Arbitration

DALLAS, Sept. 3, 2026 /PRNewswire/ -- HaloMD today released a new analysis finding that out-of-network (OON) emergency medical spending has declined between 13% to 52% since the No Surprises Act (NSA) took effect in January 2022. Even under the analysis's most conservative assumptions, OON spending was almost $1 billion lower than it would have been pre-NSA.

The research draws on publicly available data from the Brookings Institution's NSA Arbitration Databook, newly released CMS IDR Public Use Files, surveys conducted by AHIP and Blue Cross Blue Shield Association, and FAIR Health analyses. The analysis established a pre-NSA OON baseline for emergency medicine of approximately $641.71 per claim and compares that baseline against modeled post-NSA spending across claims resolved through initial payment, open negotiation and formal independent dispute resolution (IDR).

"The NSA has successfully protected patients, but this analysis shows it has also served a secondary goal of lowering medical costs," said Patrick Velliky, Chief External Affairs Officer at HaloMD. "We focused on out-of-network emergency medicine because it represents the most substantial portion of claims within the NSA framework. What we found, even under the most conservative approach to the data, is an estimated $1 billion in annual savings compared to pre-NSA amounts."

Key Findings

Applied to the approximately 11.9 million OON emergency medicine claims subject to NSA, the model finds estimated annual savings of $978 million to $3.95 billion compared to the pre-NSA baseline. Other key findings include:

1. The analysis estimated that OON emergency spending declined 13% to 52%, depending on payment rates for claims resolved without formal arbitration.
2. Most claims never reach formal arbitration. Per AHIP and BCBSA survey data covering 2024, 76% of NSA-eligible claims were resolved by the insurer's initial payment. HaloMD estimates that approximately 9.5% of OON emergency medicine claims subject to the NSA proceeded to formal IDR in 2025.
3. The mean 2025 IDR award for emergency medicine was approximately $630 per claim, which closely tracks with the analysis's estimated pre-NSA OON baseline of approximately $642.

Why the Findings Matter

The NSA was designed to protect patients from unexpected out-of-network bills and created a new process to resolve disputes between insurers and clinicians. HaloMD's analysis examines a separate question, important for all stakeholders: has the law increased or decreased medical spending?

"The data tell a clear story: when the entire out-of-network payment system is considered, arbitration is a small fraction of the whole," said Alla LaRoque, President and CEO of HaloMD. "Patients are spending less on emergency medical care today because of the No Surprises Act."

The findings carry significant implications for ongoing policy discussions surrounding the NSA. Much of the literature has focused solely on IDR awards, without accounting for the much larger volume of claims resolved through an initial payment or open negotiation. As Congress looks to refine implementation, HaloMD's analysis offers a data-driven foundation for evaluating the law's real-world impact on the broader healthcare system.

Methodology

The analysis established a pre-NSA OON baseline using historical out-of-network allowed amounts for emergency medicine compiled by the Brookings Institution. It then models post-NSA spending across two payment pathways: eligible claims resolved following an insurer's initial payment or open negotiation, and claims decided through formal IDR. Because public payment data are not available for claims subject to the NSA and eligible for the IDR process, but resolved outside of IDR, the analysis evaluates three scenarios in which those claims are paid at the qualifying payment amount, 150% of the qualifying payment amount and 200% of the qualifying payment amount. The resulting estimates are compared with the pre-NSA baseline to calculate a range of estimated annual savings.

About HaloMD
HaloMD is the #1 provider of Independent Dispute Resolution (IDR) services as indicated by public CMS data, backed by industry leading technology infrastructure and data intelligence. The company supports healthcare providers navigating the federal No Surprises Act and state balance-billing laws, combining proprietary technology, advanced analytics, and deep specialty expertise to advance fair reimbursement, long- term financial sustainability, and empowering care teams to focus on providing high quality patient care.

Privately held and founder-led, HaloMD serves more than 25,000 providers, from independent physicians to hospitals and health systems, across 50 states and Washington, D.C., so they can continue caring for the patients and communities they serve.

SOURCE HaloMD