CMS issues timeline for updated No Surprises Act dispute resolution process

CMS has published implementation timeline guidance for updates to the No Surprises Act independent dispute resolution process. The guidance outlines the phased rollout of system changes, required payer portal updates, and new data submission requirements for out-of-network payment disputes. The update addresses procedural flaws identified in recent court rulings, including deadlines for payment determinations and documentation standards for qualifying payment amounts. IDR entities and payers must adopt the updated workflow by a specified date in Q4 2026. Billing teams handling out-of-network claims should review the CMS guidance to understand the new dispute windows and documentation checklists.