HaloMD's No Surprises Act Savings Claim Draws Doubt
September 7, 2026
HaloMD Claims $1 Billion in Emergency Care Savings
A new study from billing firm HaloMD claims the No Surprises Act (NSA) has cut out-of-network emergency medical spending by at least $1 billion since the federal law took effect. Healthcare Dive reported the findings on September 2, 2026, along with pushback from independent researchers who say HaloMD's methodology has significant limitations.
The No Surprises Act is a federal law, effective since January 2022, that limits how much out-of-network providers and facilities can bill patients for emergency care and certain other services, and it bans surprise balance billing in most of those situations. It was designed to protect patients who unknowingly receive care from an out-of-network provider, such as during an emergency room visit or at an in-network hospital where an out-of-network anesthesiologist or radiologist happens to treat them.
According to Healthcare Dive, HaloMD is a billing firm, meaning it works directly with the claims and dispute data the law generates. That gives the company access to real-world billing figures, but it also means its analysis comes from inside the industry the law regulates rather than from an independent academic or government source. Healthcare Dive reported that independent experts reviewed HaloMD's study and said its methodology leaves something to be desired, without specifying in the available reporting exactly which assumptions or data gaps they flagged.
Key Takeaway
HaloMD's claim of at least $1 billion in emergency care savings under the No Surprises Act is a company-reported figure, not an independently verified government or academic finding. Healthcare Dive reported that outside researchers have raised methodology concerns, so readers should treat the $1 billion figure as a claim under review rather than a confirmed result.
How This Connects to Medicare and Medicare Advantage
The No Surprises Act primarily applies to employer-sponsored group health plans, individual and marketplace plans, and it does not govern Original Medicare or Medicare Advantage the same way. Original Medicare already limits what most providers can charge beneficiaries because it has no true provider network. Providers who accept Medicare assignment must accept the Medicare-approved amount, and non-participating providers can charge no more than 15% above that amount under Medicare's existing balance billing limit, known as the limiting charge.
Medicare Advantage plans operate differently because they use provider networks, but CMS rules already require Medicare Advantage plans to cover emergency services regardless of whether the hospital or provider is in-network, and to charge no more in cost-sharing for emergency care than a member would pay for in-network care. In effect, Medicare Advantage enrollees have had a version of surprise-billing protection for emergency visits built into federal Medicare rules before the No Surprises Act existed for the commercial market.
Where this debate becomes more relevant for Medicare Plan Path readers is the transition period around age 65, or for anyone who still carries employer, COBRA, or marketplace coverage alongside or instead of Medicare. Studies like HaloMD's, and the scrutiny they receive, shape how policymakers and insurers think about billing transparency and out-of-network cost exposure more broadly, which can eventually influence how CMS reviews Medicare Advantage network adequacy and emergency care billing rules.
What Beneficiaries Should Watch and Do Next
Readers approaching Medicare eligibility or already enrolled should keep a few practical points in mind as this research debate plays out. First, if you still have employer or marketplace coverage, the No Surprises Act's protections apply to your emergency and certain out-of-network claims now, and you can dispute an unexpected bill through your plan or the federal No Surprises Help Desk if you believe you were billed incorrectly.
Second, if you are enrolled in a Medicare Advantage plan, your emergency care cost-sharing should already match your in-network amount even at an out-of-network hospital, so an unusually high emergency bill is worth appealing directly with your plan rather than assuming it falls outside any protection. Third, if you are choosing between Original Medicare with a Medigap policy and a Medicare Advantage plan, remember that Medigap generally covers Medicare-approved providers nationwide with no network restrictions, which can simplify emergency care billing compared to a Medicare Advantage plan's network rules, though premiums and other costs differ between the two paths.
Because independent researchers are still evaluating HaloMD's savings claim, it is too early to say how much the No Surprises Act has actually reduced emergency spending industry-wide, and Medicare Plan Path will continue tracking whether follow-up research from academic or government sources confirms, revises, or contradicts the $1 billion figure. In the meantime, this is a good moment to review your own coverage's emergency care rules, whether that is a marketplace plan, a Medicare Advantage plan, or Original Medicare with Medigap, and to talk with a licensed insurance agent if you are unsure how out-of-network emergency billing would work under your specific plan.