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

Docket No.
District Court
Texas Eastern


  • Invalidate the regulation
  • Stop the government from enforcing the rule

Litigation Content

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. If federal agencies cannot set reasonable guidelines for arbitrators, certain providers could be more likely to try to abuse this process to obtain higher payments, making the arbitration process more likely to become inflationary, and leading to higher health care costs and premiums.

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.