The No Surprises Act was bipartisan achievement passed by Congress in 2020 that protected patients from unexpected medical bills when they receive emergency care or unknowingly receive treatment from an out-of-network provider. The law largely accomplished its central goal: patients should not be caught in the middle of disputes between health care providers and insurance companies over how much a service should cost.
 

But the law’s independent dispute resolution, or arbitration, process has created an unintended new challenge. When the No Surprises Act was passed, lawmakers expected arbitration to be used sparingly—roughly 17,000 cases per year. Instead, providers filed more than 2.5 million arbitration claims nationwide in 2025. In 2025, over $15B was paid in arbitration, more than triple the amount the year before, and more than six times the amount providers would have been paid if the disputed care had been delivered in-network.
 

The result is a system that can reward extraordinarily high payment demands.

For example:

• A provider sought $250,000 for an emergency department consultation that was typically reimbursed at about $1,200—and the arbitrator awarded the higher amount.

• Another provider received $37,000 for a spine CT scan that was normally reimbursed at approximately $1,500.
   

IAAHC supports reforms that preserve the No Surprises Act's critical consumer protections while ensuring providers are fairly and adequately compensated for the care they deliver. Insurers and providers should have a meaningful opportunity to negotiate reasonable payment rates, while the arbitration process should not become a pathway to reimbursement that is hundreds or even 1,000%+ above what comparable services typically cost.
 

Reforming the arbitration process can help achieve all three—and keep the focus where it belongs: providing quality care without unnecessarily increasing the cost of health insurance for Iowa families and employers.

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