On November 4, 2026, the Centers for Medicare and Medicaid Services denied recertification to two of the seventeen arbiters that run the No Surprises Act dispute process, Island Peer Review Organization and Network Medical Review Company. Neither can accept new cases, and CMS says parties with open disputes will receive separate guidance.
What Did CMS Actually Decide?
CMS, along with the Departments of Labor and Treasury, declined to renew the certification of Island Peer Review Organization, known as IPRO, and Network Medical Review Company. The decision appears on the federal government’s own list of certified independent dispute resolution entities, updated November 4, 2026, where both organizations now carry the note “Not accepting new disputes at this time.” A CMS spokesperson told reporters the two entities “did not substantially comply with the standards” that govern arbiter performance. Fifteen other certified entities remain active and continue to accept new filings.
Why Were These Two Arbiters Removed?
CMS has not published a detailed public explanation, but a July 2026 agency FAQ laid out the standard grounds for denying recertification: untimely decisions, inaccurate eligibility or payment determinations, and conflicts of interest. Both arbiters said they would consider an appeal, and both have 30 business days from the written denial notice to contest it. What makes the timing notable to practices is the arbiters’ track record. Reporting based on Turquoise Health data found that IPRO sided with the billing provider in roughly 97 percent of its decisions, among the highest provider win rates of any certified entity. Across all seventeen arbiters, physicians have won more than 85 percent of disputes since the program began in 2022, with individual firm win rates ranging from 62 percent to 97 percent.
What Happens to Disputes Already Assigned to IPRO or Network Medical Review?
Neither entity can take on new disputes, and CMS has said parties with cases still open before them will receive additional guidance from the agencies. Neither the federal list nor the reporting to date spells out whether those open cases will be reassigned to another certified entity, paused, or handled some other way. A practice with an active case assigned to either firm should expect a communication from the Federal IDR portal and should not assume the case simply continues on its original timeline.
How Big Is This Program, and Why Should a Small Practice Care?
The federal dispute process exists because the No Surprises Act bars out of network bills for emergency care and certain facility based services, leaving payment amounts to be settled through arbitration when a provider and a payer cannot agree. A Georgetown University analysis found the program had generated 22.4 billion dollars in disputed payments from 2022 through 2025, with the certified arbiters themselves collecting 742 million dollars in fees over that period simply to hear the cases. Independent and specialty practices, along with the surgical assistants and anesthesiologists who often bill alongside them, are frequent filers because arbitration is typically the only path to recovering a fair payment once a payer has underpaid an out of network claim. Losing access to one of the better performing arbiters, even temporarily, changes the odds for anyone with a case in the pipeline right now.
What This Means for Practices With 1 to 15 Providers
A small practice does not need to track arbitration policy for its own sake. It needs to know whether any open dispute is affected and what to do next.
- Pull a list of every open No Surprises Act dispute your practice or billing team has filed in the last twelve months and check which certified entity was assigned to each one.
- If a case was assigned to IPRO or Network Medical Review, call your billing contact or practice manager today and flag it for follow up. Waiting for a notice to arrive on its own wastes time you may not have.
- Do not file a new dispute naming either firm as the preferred entity. Select from the fifteen remaining certified entities on the federal list instead.
- Keep documentation of every notice CMS sends about reassignment, since a missed deadline inside the IDR process can forfeit a claim entirely.
- Treat this as a reminder to review how many out of network claims are still sitting in dispute without resolution, since each one represents revenue the practice has not yet collected.
Frequently Asked Questions
Does this affect claims billed to Medicare or Medicaid directly?
No. The No Surprises Act independent dispute resolution process applies to commercial out of network billing disputes, not to Medicare or Medicaid fee schedules.
Can my practice still use the No Surprises Act dispute process?
Yes. Fifteen other certified entities remain active on the federal list, and new disputes can be filed and assigned to any of them.
What should I do if I do not know which entity my pending case was assigned to?
Check the notice of IDR initiation your practice or billing partner received when the case opened, or log into the Federal IDR portal, which lists the assigned certified entity for every open case.
Could IPRO or Network Medical Review come back?
Both have the right to appeal within 30 business days of the denial notice. Until CMS resolves that appeal, neither can accept new disputes.
A revenue defense partner that is already watching changes like this one is the difference between finding out from a form letter and finding out before it costs a claim. See where your own exposure stands with a Revenue Defense Audit.
Sources
- CMS, List of Certified Independent Dispute Resolution Entities (updated November 4, 2026)
- Healthcare Dive, “CMS ousts 2 No Surprises arbiters as critics question impartiality,” November 6, 2026
- Medical Daily, “Federal regulators remove two surprise billing arbiters,” November 7, 2026
- Becker’s Hospital Review, “The No Surprises Act’s $22B surprise”
