On April 9, 2026, the U.S. District Court for the Central District of California handed providers an important win under the No Surprises Act. In Anthem Blue Cross Life and Health Insurance Company et al. v. HaloMD LLC, the court dismissed Anthem’s lawsuit against HaloMD and several affiliated provider defendants without leave to amend. The decision is significant because it rebuffed an increasingly common, aggressive payer strategy: attempting to use broad collateral litigation to unwind unfavorable IDR outcomes after the fact.
Anthem had sued HaloMD, a company that initiates and administers Independent Dispute Resolution (IDR) proceedings on behalf of providers, along with several affiliated provider entities, alleging a scheme to abuse the federal IDR process under the No Surprises Act (NSA).
Under the NSA, certain eligible out-of-network payment disputes proceed through a required open-negotiation period and, if not resolved, may be submitted to the federal IDR process. In this case, Anthem alleged that the defendants had initiated over 1,500 IDR proceedings covering more than 2,000 services, and claimed that nearly half of those disputes were not actually eligible for federal IDR. According to Anthem, the problems included disputes allegedly governed by California law (AB 72) rather than the federal NSA, disputes filed without the required open-negotiation period, claims involving non-covered services, and false eligibility attestations. Anthem also alleged that in hundreds of disputes, the payment offers exceeded the providers’ original billed charges.
Anthem did not merely seek review of a handful of determinations. It asserted RICO, fraud, ERISA, and related claims, and sought damages, vacatur of IDR awards, and injunctive relief aimed at stopping future allegedly improper submissions. The court rejected that approach. IDR determinations are binding except on narrow grounds, and the court held that an IDRE’s payment determination necessarily includes an eligibility determination. In other words, Anthem could raise eligibility objections within the IDR process itself, but it could not use a sweeping federal lawsuit to relitigate those disputes after the fact.
The practical takeaway for providers is that, while health plans remain free to contest eligibility within NSA IDR, they should not be able to make IDR effectively binding only when they win. For physician groups and other providers that rely on IDR to challenge inadequate out-of-network payments, that finality matters.
Although Anthem has appealed to the Ninth Circuit, the decision is both a win and a reminder for providers. The allegations in the case focused on issues plans are clearly scrutinizing: state-law applicability, open negotiation, coverage status, and the accuracy of IDR eligibility attestations. So while this decision is encouraging, clean workflows and disciplined documentation remain essential, especially with the appeal now underway.
We continue to monitor the appeal and related plan-side efforts to narrow provider use of the NSA IDR process. For now, however, this decision is a valuable provider-side ruling and a meaningful pushback against insurer attempts to unwind IDR awards through post hoc litigation.
Leech Tishman has extensive experience advising healthcare providers on reimbursement strategy and compliance, including out-of-network positioning and No Surprises Act compliance. We are prepared to assist clients in evaluating IDR-related workflows, documentation practices, and broader reimbursement strategy considerations. For assistance or additional information, please contact Harry J. Nelson at hnelson@leechtishman.com, Partner and Chair of Leech Tishman’s Healthcare Practice Group.