The No Surprises Act: 2026 Year in Review & 2027 Outlook

Course Description

The No Surprises Act (NSA) continues to shape healthcare billing, reimbursement, patient protections, and dispute resolution. As 2026 comes to a close, regulatory guidance, enforcement activity, litigation, and developments in the federal Independent Dispute Resolution (IDR) process present important compliance and operational considerations for healthcare providers, facilities, health plans, payors, and third-party administrators.

This practical year-in-review webinar will break down the most significant No Surprises Act developments of 2026 and explain how they may affect everyday compliance decisions, payment disputes, and revenue cycle performance. Attendees will review key regulatory and legal developments, revisit important applicability requirements, and explore common compliance gaps that can lead to complaints, investigations, payment delays, and unfavorable dispute outcomes.

A special focus will be placed on the evolving IDR process, including submission requirements, deadlines, batching considerations, documentation expectations, and common mistakes that can weaken a party’s position. The session will also examine Qualified Payment Amount (QPA) considerations, payment practices, audit trails, vendor coordination, and internal controls that help support defensible billing and dispute strategies.

Beyond understanding what changed in 2026, participants will gain practical insights into strengthening NSA compliance programs, improving coordination among legal, compliance, contracting, and revenue cycle teams, and minimizing avoidable operational and financial risks. Real-world scenarios and lessons from audits, investigations, and disputes will help connect regulatory developments to day-to-day practice.

The webinar will conclude with a forward-looking review of emerging issues to watch in 2027, along with actionable steps organizations can prioritize to prepare for continued regulatory scrutiny and evolving compliance expectations.

Designed for healthcare attorneys, compliance officers, revenue cycle professionals, billing and reimbursement specialists, practice administrators, provider organizations, health plans, and third-party administrators, this session will help attendees turn complex NSA developments into practical strategies for managing risk and strengthening compliance in the year ahead.

• Identify key 2026 No Surprises Act (NSA) regulatory and compliance updates.
• Recognize enforcement trends and common NSA compliance violations.
• Explain significant litigation developments and their practical implications.
• Understand 2026 changes to the Independent Dispute Resolution (IDR) process.
• Identify common IDR submission errors, missed deadlines, and documentation gaps.
• Apply best practices to strengthen IDR submissions and dispute outcomes.
• Understand Qualified Payment Amount (QPA) requirements and payment considerations.
• Evaluate the impact of NSA developments on billing, contracting, and revenue cycle operations.
• Identify audit risks and implement effective NSA compliance controls.
• Prepare for emerging 2027 NSA regulatory changes and compliance priorities.

• 2026 No Surprises Act Regulatory Updates
• Key federal updates and agency guidance
• New requirements vs. unchanged rules
• Practical compliance implications
• NSA Scope and Applicability
• Emergency and non-emergency services
• Out-of-network providers and facilities
• Exceptions, exclusions, and edge cases
• 2026 Enforcement Trends and Penalties
• Federal enforcement priorities
• Common compliance violations
• Audit findings and corrective actions
• Independent Dispute Resolution (IDR) Updates
• Current IDR process and requirements
• Submission deadlines and eligibility
• Operational changes and common delays
• IDR Strategy for Providers and Health Plans
• Building stronger dispute submissions
• Negotiation and arbitration strategies
• Avoiding procedural disqualifications
• Qualifying Payment Amount (QPA)
• QPA calculation methodology
• Documentation and supporting data
• Common calculation and reporting disputes
• Key NSA Litigation and Court Decisions
• Significant legal challenges
• Court rulings affecting IDR and QPA
• Implications for future disputes
• Payment Disputes and Reimbursement Challenges
• Underpayment and payment disagreements
• Open negotiation requirements
• Strategies for resolving disputes
• NSA Compliance for Health Plans and Insurers
• Payment and notice obligations
• Internal controls and compliance monitoring
• Vendor and third-party administrator oversight
• Provider and Facility Compliance
• Patient billing protections
• Notice and consent requirements
• Preventing improper balance billing
• Revenue Cycle and Billing Risk Management
• NSA-related billing errors
• Denial and underpayment management
• Revenue leakage prevention
• Contracting and Network Management
• Out-of-network payment provisions
• Contract language and reimbursement terms
• Managing payer-provider disputes
• Documentation, Audits, and Recordkeeping
• Evidence supporting payment positions
• Audit trails and record retention
• Preparing for regulatory reviews
• Operational Challenges and Best Practices
• IDR workflow and deadline tracking
• Data quality and case management
• Performance metrics and process improvements
• 2027 NSA Outlook and Action Plan
• Emerging regulatory and litigation trends
• Anticipated compliance challenges
• Priorities for strengthening NSA programs
• Interactive Live Q&A session

• Fighting Back Against Recoupments: Prevent E/M Documentation Errors, Survive Audits & Protect Revenue
• Mastering Payor Contract Negotiation: Strategic Approaches for Maximizing Reimbursement

• General Counsel, Deputy General Counsel, and Healthcare Attorneys
• Healthcare Regulatory Counsel and Regulatory Affairs Professionals
• Chief Compliance Officers and Compliance Program Directors
• Healthcare Compliance Managers and Compliance Analysts
• Revenue Cycle Executives, Directors, and Managers
• Patient Financial Services (PFS) Directors and Managers
• Billing, Collections, and Reimbursement Managers
• Patient Access, Registration, and Financial Clearance Leaders
• Managed Care and Payer Contracting Directors
• Provider Relations and Network Management Professionals
• Independent Dispute Resolution (IDR) and Arbitration Program Managers
• Claims Appeals, Grievances, and Disputes Managers
• Health Plan Claims Operations and Payment Policy Leaders
• Claims Pricing, Configuration, and Payment Integrity Specialists
• Physician Practice Administrators and Healthcare Operations Leaders
• Coding, Charge Capture, and Clinical Documentation Improvement (CDI) Managers
• Health Information Management (HIM) and Data Governance Professionals
• Internal Audit, Risk Management, and Regulatory Audit Professionals
• Hospital and Health System Administrators, including Emergency Medicine, Anesthesiology, and Radiology Leaders
• Third-Party Administrator (TPA) Representatives and Healthcare Payer Operations Professionals

Megan K. McKisson, Esq. is a healthcare litigator at Sheppard Mullin Richter & Hampton LLP with extensive experience representing leading health plans in high-profile federal litigation and statutory arbitration matters. Her practice focuses on complex healthcare disputes, regulatory compliance, and reimbursement issues, with particular emphasis on matters arising under the No Surprises Act (NSA).

Megan has handled numerous first-impression cases involving the NSA, providing clients with strategic guidance on the law’s evolving requirements and its impact on provider-payer relationships. She regularly advises health plans and other healthcare stakeholders on compliance obligations, dispute resolution strategies, arbitration proceedings, and litigation risks related to out-of-network reimbursement disputes.

As the regulatory landscape continues to evolve, Megan helps organizations navigate emerging federal requirements, interpret new regulations, and develop practical approaches to managing compliance challenges. Her experience spans both litigation and arbitration, giving her a comprehensive understanding of the legal and operational issues that affect healthcare payers and providers.

Drawing on her hands-on experience with some of the most significant NSA-related disputes and regulatory developments, Megan brings valuable insights into the latest changes affecting the federal IDR process, payer obligations, and healthcare reimbursement practices.