Issue / Topic: No Surprises Act

Qualifying Payment Amount

5 tracked cases

Spotlight

Key quotes shaping this topic

“The agencies’ error has upended the NSA’s dispute-resolution process. Congress intended the QPA to serve as a focal point of providerinsurer negotiations as to which party would cover the balance of a patient’s bill. Because the agencies directed insurers to include non-negotiated ghost rates, the resulting QPAs were artificially low. ”

Texas Medical Association et al. v. Department of Health and Human Services et al. (TMA III)
Fifth Circuit, 2026

Who's Suing

Plaintiff by Type

Who's Being Sued

Defendant by Type

Who's Suing

Plaintiff by Type

Who's Being Sued

Defendant by Type

Legal Issues

Statutes & Doctrines Cited

Legal Issues

Statutes & Doctrines Cited

Geographic Trends

3 active district courts

1 active circuit court

Not shown: Puerto Rico (First Circuit), the U.S. Virgin Islands (Third Circuit), and Guam and the Northern Mariana Islands (Ninth Circuit).

Court Level

Appellate District

1 (20%) 4 (80%)

Status

Who's Presiding

District Court Cases by Appointing President

Reflects district court judges only.

Health Affairs

Fifth Circuit Invalidates Two More Provisions Of No Surprises Act Rule

Health Affairs

The No Surprises Act IDR Process: An Early Look At 2025 Data

Health Affairs

The No Surprises Act: A Litigation Status Check

Health Affairs

Fifth Circuit Hands Administration Victory In No Surprises Act Litigation

O'Neill Institute

Latest Twists and Turns in No Surprises Act Litigation: What it Means for Consumers and Ongoing Implementation

O'NEILL INSTITUTE

Continued No Surprises Act Litigation and Implications for Cost Containment Efforts

HEALTH AFFAIRS

Provider Groups Each Bring Third Lawsuit Challenging No Surprises Act

All trend data is based solely on the cases on this website; if you want to recommend a new case to include, please let us know at hpli@georgetown.edu.