Texas Medical Association et al. v. Department of Health and Human Services et al. (TMA I)

Why this Matters
The plaintiffs argue that regulations to impose guardrails on the No Surprises Act’s arbitration process—a process used to resolve payment disputes for surprise out-of-network bills between payers and out-of-network health care providers—are invalid under the Administrative Procedure Act. In this appeal, the defendants argue that the district court erred in siding with the plaintiffs and finding the regulations unlawful.

Potential Impact
The inability to impose reasonable guardrails for the No Surprises Act’s arbitration process could lead to abuses of the process and higher health care costs and premiums.