With no warning and no apparent sense of irony, on Dec. 23, the Centers for Medicare and Medicaid Services (CMS) surprised the medical community with a substantial change in the No Surprises Act (NSA). The act, which was supported by the medical community, was passed to protect patients from unexpected out-of-network medical bills that they could not reasonably anticipate or avoid. On the Friday before the long holiday weekend, CMS stated that if providers wish to appeal an underpayment from health insurance companies by requesting arbitration (termed “independent dispute resolution” or “IDR”), the administrative fee they are required to pay would be increasing by 600 percent. This cha
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