What it now takes to win out-of-network disputes in the next phase of the No Surprises Act

Since 2022, providers and payers have worked to master the No Surprises Act’s independent dispute resolution process—its eligibility rules, batching limits, deadlines, and documentation standards. Now the next phase has arrived.

Those changes are already reshaping out-of-network recovery. The fee to dispute a claim has dropped sharply, a new centralized platform is replacing today’s single-use dispute forms, and new coding requirements take effect in 2027. Each raises the stakes on getting the process right—and the cost of falling behind.

The providers who pull ahead treat these shifts as an operational discipline, not a scramble. This whitepaper breaks down what out-of-network recovery now requires, and how to:

  • Own the full dispute lifecycle so no claim stalls on a missed deadline
  • Pair automation with expert review to build stronger, review-ready cases
  • Turn regulatory change into a competitive advantage