ASA Urges Swift Release of Final IDR Operations Rule to Stabilize No Surprises Act Implementation

On October 20, 2025, the American Society of Anesthesiologists (ASA), alongside the American College of Emergency Physicians (ACEP) and the American College of Radiology (ACR), formally urged the Departments of Treasury, Labor, and Health and Human Services to release the long-awaited Independent Dispute Resolution (IDR) Operations Final Rule. The proposed rule, originally published in November 2023, includes critical reforms to streamline the federal IDR process under the No Surprises Act and address ongoing inefficiencies that have disrupted fair payment resolutions for out-of-network care.

In their joint letter, the organizations emphasized that delays in finalizing the rule have prolonged instability in the IDR system, with insurers failing to comply with statutory requirements and certified IDR entities inconsistently applying regulations. ASA and its partners strongly support the proposed enhancements, including improved disclosure requirements, mandatory use of standardized claim codes (CARCs and RARCs), and reforms to the Open Negotiation process. These changes would reduce administrative burdens, improve transparency, and ensure that patients remain protected from surprise billing disputes.

The letter also highlights the need for stronger enforcement mechanisms. ASA and its co-signers called on the Departments to implement civil monetary penalties for noncompliance, particularly in cases where insurers fail to pay awarded amounts within the required timeframe. They also urged the Departments to conduct the random audits mandated by the No Surprises Act and publish annual reports to ensure accountability across all stakeholders.

ASA joins ACEP and ACR in requesting that the final rule be released in November 2025, with key provisions—such as batching updates and disclosure requirements—taking effect within 30 days of publication. These operational improvements are essential to restoring confidence in the IDR process and ensuring that physicians can continue to deliver high-quality care without undue financial disputes. ASA remains committed to advocating for fair, transparent, and efficient implementation of the No Surprises Act.