The No Surprises Act (NSA) was created to protect patients from a number of surprise medical bills — such as for emergency treatment by out-of-network providers at in-network facilities. However, recent layoffs at the federal agency responsible for enforcement may have put those protections at risk. With fewer regulators and mounting dispute volume, oversight is weakening, leading to more billing conflicts, longer delays in adjudication of surprise charges.
In early 2025, the Center for Consumer Information and Insurance Oversight (CCIIO)—the federal agency tasked with overseeing NSA compliance—reduced its workforce by 15%. Additional cuts have followed. The result? Fewer staff to manage disputes, enforce rules and respond to plan sponsors or patient concerns. With more than 650,000 NSA disputes filed by medical providers in 2023 alone, this under-resourced arbitration system is showing signs of collapse.
For employers, plan sponsors and third-party administrators, that means increased exposure. Without strong oversight, providers may push the boundaries on out-of-network billing, delay resolution or avoid compliance altogether. It also leaves plan sponsors and participants more vulnerable to increases in the cost of coverage.
Why This Matters for Self-Insured Plans
Self-Insured health plans are already carrying a heavy administrative and financial load. Weakened federal enforcement will likely increase the number of billing disputes and the challenged amounts.
Without a trusted partner, plans face:
- Increased out-of-network billing risk.
- Delayed or inconsistent dispute resolution.
- Higher legal and administrative costs.
- Greater participant dissatisfaction and confusion.
aequum Is Filling the Gap
As federal oversight falters, aequum is stepping up. Our legal and cost-containment teams are built for this moment—prepared to defend plan participants, manage Independent Dispute Resolution (IDR) processes and recover overpayments that would otherwise go unchecked.
aequum supports more than 425 self-insured plans across all 50 states. Our services include:
- Balance bill defense: shielding participants from unfair charges
- Claims dispute management: navigating complex billing conflicts
- Regulatory compliance support: staying current with NSA developments
- Overpayment recovery: ensuring plan assets are protected
Now is the time for a proactive strategy of interdiction — not reactive crisis management. aequum is calling on federal officials to do the same: reinstate enforcement staff, finalize long-delayed IDR updates and increase transparency across the system.
Stay Ahead of the Risk
The healthcare landscape is shifting fast and the rules designed to protect your plan and your participants are only as strong as the systems enforcing them. With federal capacity stretched thin, self-insured plans need to act.
Partner with aequum to safeguard your organization from rising legal risk, financial exposure and surprise medical bills. We’ll help you stay compliant, in control and ahead of what’s next.
Contact us today to learn how aequum can help protect your health plan in this new enforcement environment.