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Study: Emergency care costs fall up to 52% after No Surprises Act

A new analysis from HaloMD provides evidence that the No Surprises Act is working to cut costs, with data indicating about $1B in savings from out-of-network emergency care.

Jacqueline LaPointe
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Published: 03 Sep 2026

The No Surprises Act is working as intended, reducing out-of-network costs by nearly $1 billion, according to a new analysis from HaloMD.

Costs for emergency medical spending are down 13% to 52%, the analysis found. This is all after the implementation of the NSA, suggesting lower spending on emergency care than would have occurred if the law had not existed.

The analysis used publicly available data from the Brookings Institution, CMS IDR Public Use Files, surveys conducted by America's Health Insurance Plans and Blue Cross Blue Shield Association and FAIR Health analyses to compare costs before and after the landmark law. It focused on out-of-network emergency medicine, the most targeted area for disputes.

Approximately 11.9 million out-of-network emergency medicine claims were subject to the NSA, resulting in annual savings of about $978 million to $3.95 billion compared to a pre-NSA baseline, the analysis found.

The analysis comes just days after research from Georgetown University showed that the federal IDR process has generated $22.4 billion in additional costs over just four years. The excessive spending was driven by the sheer volume of disputes, which increased by 77% from 2024 to 2025, as well as rising payment amounts, which grew by 264% over the same period.

The Georgetown research has added fuel to the NSA fire, as payers and patient advocacy groups push for IDR reform. They say the federal process has increased healthcare spending, particularly as private equity and so-called middleman companies game the system.

HaloMD is one of those middleman companies, helping more than 25,000 providers navigate the federal IDR process and state balance billing laws to get reimbursed for out-of-network care. The company itself has been sued by several large insurers, including Elevance Health, Blue Cross Blue Shield of Texas and Highmark Health, over allegations it has flooded the IDR process, particularly with ineligible claims, and used misleading pricing data to garner outsized payments.

The company has denied all wrongdoing, defending its business practices as shielding medical practices from payers that deliberately give lowball offers for out-of-network care. Federal courts have also consistently sided with HaloMD, dismissing multiple insurer lawsuits in California, Texas and Georgia.

Analysis paints a different picture of IDR impact

Now, HaloMD says that its analysis of healthcare spending under the NSA paints a more accurate picture of the law's efficacy. Lawmakers wanted the law not only to protect patients from surprise medical bills but also to reduce overall healthcare spending.

The law has done that, according to Alla LaRoque, HaloMD's president and CEO.

"The data tell a clear story: when the entire out-of-network payment system is considered, arbitration is a small fraction of the whole," she said in a press release. "Patients are spending less on emergency medical care today because of the No Surprises Act."

Most claims never reached the formal IDR process, HaloMD reported, citing a survey by AHIP and BCBSA that found about three-quarters of NSA-eligible claims were resolved with the payer's initial payment in 2024.

The analysis estimated that approximately 9.5% of out-of-network emergency medicine claims were subject to the IDR process in 2025. And when these claims went through the process, the mean award was about $630 per claim, close to the pre-NSA out-of-network baseline of nearly $642, HaloMD reported.

The analysis did not examine the impact the NSA has had on in-network rates, which lawmakers believe will generate most of the cost savings associated with the law. However, it stated that the decrease in emergency out-of-network costs after the NSA fell by 2.1% to 9.1%, including in- and out-of-network costs.

Overall, the findings highlight a side of the IDR story that the literature and media don't often cover, the company suggested.

"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," the press release explained. "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."

The IDR process is undergoing a major overhaul under a rule finalized by the federal government in May. The rule addresses some of the process's major challenges by lowering administrative fees, creating an official IDR registry to better track open negotiations and disputes and tightening batching limitations.

Healthcare providers have welcomed many of the changes, saying the process is more affordable and increases transparency about which claims are eligible and how payers make decisions.

However, concerns remain about the operational fixes, with providers still frustrated with how payers calculate qualifying payment amounts to give to arbitrators for payment determinations. Notably, a federal appeals court recently overthrew the QPA's calculation method, siding with providers challenging ghost rates used in the formula.

Meanwhile, payers were dissatisfied with the final rule, fearing another tsunami of disputes that would add to the existing backlog. They also said the rule failed to address provider abuse of the process.

The HaloMD analysis adds to a growing body of literature pointing to the NSA's success, including a February report from the Government Accountability Office that found greater provider participation in health plan networks after the law. This suggests fewer surprise medical bills for patients despite payers cautioning that the law could incentivize providers to leave networks.

Jacqueline LaPointe is an Executive Editor at Xtelligent Healthcare Media, covering revenue cycle management, healthcare payers, health policy and health IT since 2016.

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