No Surprises Act in Focus
There is a growing chorus of actors focused on changes to the No Surprises Act (NSA). NSA was designed to end surprise billing for consumers in the commercial market. Arbitration filings have exceeded expectations with the number of arbitrations continuing to accelerate. Additionally, recent research has found the NSA is reducing incentives for providers to participate in insurer networks and may be increasing pressure on insurers to raise premiums. A coalition of employers, patient advocates, and unions are lobbying Congress to change the NSA and reduce premium increases. Conversely, a coalition of providers is lobbying to increase penalties on insurers for noncompliance with NSA requirements and help providers.
HHS OIG Medicare Advantage Investigations
HHS Office of the Inspector General (OIG) recommended that UnitedHealthcare of Wisconsin refund $46.9 million over alleged unsupported diagnoses. OIG also estimated HumanaChoice received $130.9 million in MA overpayments. OIG is also investigating MA plans’ Medicare Advantage coding practices (i.e., this is happening in addition to CMS RADV activities).
CMS Expands ACCESS
CMS announced that beginning in spring 2027, its ACCESS Model will add heart failure, COPD, substance use disorders, and nicotine dependence, while extending support for musculoskeletal conditions. ACCESS pays participating technology-enabled providers based on patient outcomes rather than conventional fee-for-service volume. More than 160 organizations are currently listed as participants, and CMS says private payers representing 165 million members across MA, Medicaid, and commercial coverage have committed to aligning with the model’s payment approach.
Economy Update
- The Federal Reserve raised interest rates a quarter of a percentage point this week. Interest rate increases put upward pressure on consumer loans (i.e., mortgage, auto loans, credit card, etc.) and increase the cost for corporations to finance loans.
- The reason for the interest rate increase is continued higher inflation. The expectation is that gas prices will continue to climb in coming weeks. From a health care perspective, higher inflation, especially for gas and food prices, can put downward pressure on elective procedures.

