As the 'No Surprises Act' (NSA) was intended to shield patients from unforeseen healthcare costs, the recent interpretation by the Centers for Medicare & Medicaid Services (CMS) sparks serious concerns for the healthcare industry(1). Unveiling a IDR administrative fee hike of 600% (2), this latest move unduly burdens healthcare providers and professionals, while disproportionately benefiting insurance payers (3). This shift is not only contradicting the spirit of the NSA but also further amplifying the struggles faced by physicians, nurses, and healthcare staff.

Healthcare providers are already grappling with significant challenges. They must navigate a complex administrative labyrinth, often with limited resources, to comply with insurance procedures and meet the NSA's requirements. Nurses and healthcare staff are caught in the crossfire, working longer hours, facing increased administrative duties, and struggling with mounting work-related stress. While these professionals strive to provide optimal patient care, they are being thrust into a financial tug-of-war that directly impacts their ability to do so effectively.

Insurance premiums and deductibles have been on an alarming upward trajectory for years. According to the 2022 benchmark KFF Employer Health Benefits Survey, annual family premiums for employer-sponsored health insurance average $22,463 this year(4). Meanwhile, workers are contributing an average of $6,106 towards the family premium, and the average annual deductible for single coverage stands at $1,763, which is a 61% increase since 2012(4).

In this landscape, insurance companies are recording record profits from the high premiums, while concurrently reducing their financial responsibilities towards healthcare providers. This dynamic contradicts the NSA's intended purpose and raises grave concerns about a system that seems to favor the interests of insurance companies over those delivering care.

As these challenges persist, the viability of the healthcare system comes under threat. Healthcare providers, who tirelessly work on the frontlines to deliver essential services, find their financial health jeopardized. This not only challenges the survival of smaller healthcare practices but also risks compromising the quality of patient-centric care.

While the NSA emerged as a promising step towards a more equitable healthcare system, the recent interpretation by CMS veers away from its path(1). The collective voice of healthcare professionals, patients, and advocates must insist on a fair compensation structure for healthcare providers and an equitable healthcare system that does not disproportionately favor any single stakeholder. It is imperative that we maintain a balance within the system, ensuring the profitability aligns with responsibility, and fostering an environment that promotes quality care over financial gain.

The financial stability of our healthcare providers, nurses, and staff isn't just about fairness - it's about the health of our nation. These professionals are the backbone of our health system, and their struggles significantly impact the quality and availability of healthcare services. To support them is not only an ethical obligation, but a necessity for a healthy, functioning society. It is high time we realign our healthcare system to reflect this vital truth.


The current interpretation of the 'No Surprises Act' by CMS presents a profound disconnect between its original purpose and the reality of its implementation. Healthcare providers, nurses, and staff - the heart and soul of our healthcare system - find themselves caught in an increasingly complex and challenging environment. While insurance companies continue to enjoy soaring profits, those responsible for delivering care to patients are bearing the brunt of the systemic imbalances. This not only risks the quality of care delivered to patients but also threatens the financial sustainability of our healthcare system. In this context, it's crucial to reevaluate the current interpretation of the 'No Surprises Act' and realign it with its intended purpose: to protect patients from unforeseen costs without overburdening those who provide care. This is not just about the fair treatment of healthcare providers but also about safeguarding the long-term viability of patient-centric healthcare in our nation. We must persist in advocating for a healthcare system that acknowledges and supports its essential human element - our dedicated healthcare professionals. By doing so, we can ensure that our healthcare system remains resilient, equitable, and capable of delivering excellent care to all.


  1. CMS Response to Out Increased Admin Fee Letter:
  2. Amendment To The Calendar Year 2023 Fee Guidance For The Federal Independent Dispute Resolution Process Under the No Surprises Act:
  3. EDPMA ACEP 2023 IDR Admin Fee Comments:
  4. Annual Family Premiums for Employer Coverage Averages this year:

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