Akerman Healthcare Practice Group Partner Christopher Pinto and Associate Ameer Al-Khudari contributed an article to Law360 analyzing the regulatory landscape and compliance challenges expected to define the No Surprises Act in 2026 and beyond.
In "Prepping For The Future Of No Surprises Act Enforcement," Christopher and Ameer identify three critical areas federal agencies are expected to prioritize: finalizing delayed rulemaking, issuing guidance to address operational challenges in the independent dispute resolution process, and managing enforcement discretion amid ongoing litigation. They note that despite the law being signed in December 2020, numerous statutory provisions remain unimplemented, creating continued regulatory uncertainty for health plans, providers, and other stakeholders. Drawing on recent regulatory developments and ongoing litigation, Christopher and Ameer offer practical guidance for health plans, providers, and independent dispute resolution entities, emphasizing the importance of proactive compliance planning and building internal review processes in advance of anticipated enforcement activity.