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American Association of Oral and Maxillofacial Surgeons Oral and maxillofacial surgeons:
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The No Surprises Act (NSA) introduced a two-part process to address and resolve disputes over out-of-network reimbursement between providers and payers. Since the creation of the NSA in 2022, the guidance and operations of these processes have expanded. This resource is designed to help OMSs and their staff navigate the federal arbitration process under the NSA.

Because  interpretation of law and regulation carries legal ramifications,  information provided by AAOMS is not intended as legal advice. OMSs should consult their practice attorney regarding the NSA to determine how both federal and state laws affect their practice.

Operations

The Departments issued a Final IDR Operations Rule in May 2026 that introduces the IDR Gateway, a single platform where users can manage disputes, track the status of a case and manage activity. This platform will be operational by the end of 2026 and will be used to start and respond to disputes, access dispute dashboards and reports associated with their organization, track dispute information, monitor assigned disputes by process phase and review notifications regarding dispute activity. This platform also will be used to initiate the open negotiation process.

The dispute resolution process is specific to situations where the Qualifying Payment Amount (QPA) is applied as the out-of-network payment rate. In cases where an all-payer agreement exists, or specified state laws are in place to determine out-of-network rates and handle disputes, the NSA dispute resolution process does not apply. Also, services for which a notice and consent waiver was utilized, as permitted under the NSA, are not eligible for the federal dispute process.

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