No Surprises Act Disputes: What the Supreme Court's Decision Means for High-Cost Claims

Legal uncertainty around the No Surprises Act continues to grow, and recent developments reinforce an important reality for employers, TPAs and stop-loss carriers. Dispute processes are not a safety net for missed claim oversight.

At HHC Group, we are closely following developments related to the No Surprises Act because of our direct involvement in dispute resolution and claim review and negotiation for payors navigating NSA eligible, out-of-network claims.

HHC Group recognizes that the Supreme Court's decision does not weaken the No Surprises Act. It clarifies its limits. Plans cannot depend on dispute mechanisms or enforcement actions to correct issues after payment decisions are made. The strongest protection comes from proactive review, informed negotiation and human oversight applied early. NSA related, out-of-network claims are rising. Regulatory scrutiny is intensifying. Reliance on automation alone is no longer enough.

Here's the Background

In January, the U.S. Supreme Court declined to hear a case involving whether providers can enforce NSA independent dispute resolution (IDR) awards against insurers through private lawsuits. By stepping aside, the Court left intact a lower court ruling that limits enforcement of IDR outcomes to administrative channels rather than the courts.

While the case focused on provider rights, the implications extend well beyond litigation strategy, especially for those responsible for paying and defending NSA claims involving out-of-network services.

Why This Ruling Matters in Practice

The NSA was designed to remove patients from surprise billing disputes by creating a structured resolution process between payors and providers. However, this decision reinforces that:

• IDR awards are binding administratively, not easily enforced through private court action.
• Enforcement authority largely rests with federal agencies.
• Litigation is not a reliable fallback when payment disputes arise.

In short, what happens after a claim is finalized offers limited protection. Once a payment decision is made, leverage narrows and options become constrained.

The Real Risk: Waiting Until the Back End

Many organizations assume that automated workflows, statutory protections or post-payment dispute mechanisms will naturally lead to fair and defensible outcomes.

This ruling highlights the risk in that assumption.

When high-cost claims are:

• Paid quickly to keep operations moving.
• Reviewed without medical-record-level scrutiny.
• Allowed to proceed unchallenged because "the process handled it."

Errors, inflated charges and missed negotiation opportunities can become permanent. In today's environment, speed without strategy creates exposure.

Where Early Oversight Makes the Difference

This is where HHC Group plays a critical role.

HHC Group helps TPAs, stop-loss carriers, brokers and plan sponsors review, negotiate and defend NSA and other high-cost out-of-network medical claims early, before leverage disappears and savings are lost. Our focus is on getting claims right the first time, rather than relying on dispute resolution or enforcement remedies after the fact.

Our approach includes:

• H.H.C. Group Attorney-Led Negotiation: All HHC Group negotiators are licensed health insurance adjusters who have passed rigorous state examinations and specialized training. These professionals are attorney-led, ensuring each negotiation reflects legal, regulatory and contractual requirements. This structure means every claim is handled by certified individuals, not just a certified company, bringing accountability, credibility and experience to every engagement.
• Certified Coder and Licensed Pharmacist Review: Our experts combine coding precision, pharmacy expertise, and ISO-certified quality controls to scrutinize each line item for accuracy and compliance, ensuring payment aligns with clinical necessity, contract terms and pricing integrity.
• 30+ Years of Relationships and Results: With more than three decades of experience, we've built professional relationships with providers nationwide. They take our calls because they know we're fair, fact-based and prepared. That credibility helps us reach faster resolutions and achieve meaningful savings without unnecessary escalation.

This level of scrutiny not only drives savings but also supports defensible, well-documented claim decisions in an environment of increasing fiduciary and regulatory pressure.

Don't Wait Until Leverage Is Gone

Every large claim presents a narrow window to verify accuracy, challenge assumptions and secure fair outcomes. If your current process assumes claims are already being reviewed closely enough, this ruling is a reminder to take a closer look.

HHC Group helps ensure high-dollar claims receive the scrutiny today's environment demands, before options narrow and savings disappear.

Don't walk away from savings you should be capturing.

Contact HHC Group today to discuss your high-cost claims strategy and see how early, human-led oversight can make the difference.