CMS has logged nearly 40,000 complaints alleging potential violations of federal health insurance law since the agency began tracking them in 2022, with the vast majority of closed complaints related to the No Surprises Act, according to an enforcement report covering data through December 2025.
The report tracked complaints under Title XXVII of the Public Health Service Act, which includes the NSA, Mental Health Parity and Addiction Equity Act, and ACA compliance.
The agency closed 15,145 complaints in total, which were defined broadly to include stakeholder feedback, congressional and state referrals, No Surprises Help Desk submissions, and news articles. Of those, 2,086 were closed with a violation found and 7,838 with no violation found; the remainder were duplicates or withdrawals. Complaints referred to other agencies were not included in the data.
The majority (14,799) of the closed complaints were related to the NSA, with 11,417 of those filed against providers, facilities, or air ambulance services. Surprise billing for non-emergency services at in-network facilities was the single most common complaint against providers, at 4,806 cases. The second most common complaint (2,363) was surprise billing for emergency services.
Among the 3,219 closed NSA complaints against payers, the most common (844) involved noncompliance with QPA requirements. The second most common complaint against payers (664) involved late payment following an IDR determination.
CMS enforcement actions have produced nearly $30 million in direct relief stemming from all closed investigations. Nearly 25,000 complaints were open at the time of the report’s publication.
The report comes shortly after federal agencies finalized a major overhaul of the independent dispute resolution process in late May that established a centralized disputes portal and a new federal payer registry, along with a reduction in dispute administrative fees. Providers have been winning roughly 85% to 88% of disputes, with median payment determinations reaching 459% of the QPA in 2024.
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