Employer- and union-sponsored group health plans, their fiduciaries, third-party administrators (TPAs) and administrative services-only (ASO) vendors should take immediate actions ensure their health plan’s compliance under the No Surprises Act (“NSA”) responsibilities in response to new final rules and emerging data suggesting many health plans and their fiduciaries already are incurring signficantly increased cost and other unrecognized liability risks from liabilities preexisting NSA compliance deficiencies.

• First, the Departments of Health and Human Services, Labor and the Treasury and the Office of Personnel Management have finalized sweeping changes to the No Surprises Act (NSA) Federal Independent Dispute Resolution (IDR) process — including retirement of the current single-use web forms in favor of a new online case-management platform, the “IDR Gateway.”
• Second, and just as urgent, mounting federal court rulings and IDR performance data are exposing widespread payer- and TPA-side compliance failures that are driving actual 2026 out-of-network (OON) claim costs well above what many plans budgeted.
• Plan sponsors and fiduciaries should treat this as a multi-pronged project:
• Get ready for the new rules and Gateway and confirm plan documentation, communications, vendor contracts, out-of-network cost forecasts and processes are legally compliant and operationally ready to manage out-of-network costs and liabilities; and
• Assess your health plan’s 2026 out-of-network claims to evaluate if legal, operational or other weaknesses in your 2026 plan year reference based pricing or other claims assumptions, forecasts or administration have or are likely to expose your plan to higher than projected costs and other financial and legal exposures.

Part 1 — The IDR Gateway Transition & New Final Rule Required Updates

The Final Rule: What Changed

On May 28, 2026, HHS, the Department of Labor, the Department of the Treasury and OPM finalized the “Federal Independent Dispute Resolution Operations” rule, published June 4, 2026 at 91 Fed. Reg. 33900 (RINs 0938-AV15, 1210-AC17, 1545-BQ55 and 3206-AO48), amending 45 C.F.R. Part 149, 29 C.F.R. Part 2590, 26 C.F.R. Part 54 and 5 C.F.R. Part 890. See also the CMS Fact Sheet and CMS Press Release announcing the rule. The rule is intended to speed up dispute resolution, cut costs and improve transparency in the process health plans, providers and IDR entities use to resolve payment disputes over certain out-of-network claims under the No Surprises Act. Key operational changes include:

• Lower administrative fees. The per-party administrative fee to initiate a dispute drops from $115 to $15 — an 85% reduction — effective approximately June 11, 2026 (five business days after publication).
• Revised batching rules. Claims may be batched in three new circumstances (same-patient/consecutive-date services on one claim; identical or comparable procedure codes across systems; and certain anesthesiology, radiology, pathology and laboratory services within the same CPT category), subject to a new 50-line-item cap per dispute.
• Portal-based open negotiation. Open negotiation notices must be submitted through the Federal IDR portal, starting the 30-business-day negotiation clock on submission, with a response notice due from the recipient by business day 15.
• Faster eligibility determinations. Certified IDR entities must determine dispute eligibility within 5 business days of being selected — a firm deadline where none previously existed.
• Standardized claim codes. Payers must communicate using standardized claim adjustment reason codes/remittance advice remark codes (CARC/RARC) on No Surprises Act claims, helping providers identify IDR eligibility earlier.
• New IDR Registry. Payers will be required to register and obtain an assigned registration number to support provider identification and CMS enforcement tracking.

See CMS Fact Sheet, Federal Independent Dispute Resolution Operations Final Rule; 91 Fed. Reg. 33900 (June 4, 2026)

As these changes are being phased in with some already effective and others scheduled to rollout over the next few months in future agency guidance, plans must update policies and practices for changes already effective, while keeping a watch out for and building the compliance infrastructure to meet each future change by its deadline as CMS issues additional guidance. Pending future guidance, Plans need to act now to respond to the currently issued rules:

• The general rule took effect August 3, 2026;
• The reduced fee is already in effect; and
• The final rules on batching, portal-based negotiation/eligibility, and Registry provisions take effect on rolling 90-day (or 90-business-day) timelines tied to forthcoming CMS guidance and system-functionality announcements.

Coming Soon: The IDR Gateway

In late 2026, the Federal IDR process will transition from single-use web forms to the new IDR Gateway, a secure, centralized platform for managing disputes. According to CMS, SeeCMS, “Coming Soon: IDR Gateway,” cms.gov/nosurprises/notices

According to CMS, the IDR Gateway users will be able to:

• Start and respond to disputes;
• Access dispute dashboards and reports associated with their organization;
• Track dispute information, including disputes assigned to a certified IDR entity;
• Monitor assigned disputes by process phase; and
• Review notifications regarding dispute activity.

The Gateway also adds new security features, including identity verification and protocols limiting access to the Federal IDR process to U.S.-based users.

Who Must Sign Up

Organizations and individuals that process disputes, represent parties, or submit IDR web forms in the current Federal IDR process must sign up to manage disputes in the IDR Gateway. If a plan or issuer uses a TPA or other organization to process disputes on its behalf, the plan itself does not need to sign up — but it must confirm that the TPA or other organization responsible for managing its dispute-processing activities has signed up for an IDR Gateway account. Plan sponsors and fiduciaries relying on a TPA or ASO vendor should get this confirmation in writing.

Details about signing up for the IDR Gateway are still forthcoming from CMS. Until sign-up instructions are released, parties should continue using the existing Federal IDR web forms.

Recommended IDR Gateway Action Steps for Plan Sponsors, Fiduciaries and Administrators

1. Select your IDR Gateway administrator(s) now. Every organization that will use the Gateway should designate at least one administrator (CMS recommends two; no more than ten) to set up the organization’s Gateway account before the September 15, 2026 account-creation window opens.
2. Confirm who is responsible for signing up. Where a TPA or other vendor handles IDR disputes on the plan’s behalf, obtain written confirmation that the vendor will register for its own IDR Gateway account and has a compliance plan in place.
3. Watch for CMS outreach. The Federal IDR Team will email selected administrators instructions for creating accounts and setting up the organization. If your organization designates an administrator who does not receive that email, contact IDRGatewayHelp@cms.hhs.gov.
4. Update plan documents and claims/disputes procedures. Revise summary plan descriptions, claims and appeals procedures, and internal desk procedures to reflect the new $15 administrative fee, revised batching rules, portal-based open negotiation timelines, and standardized CARC/RARC code communications.
5. Refresh fiduciary oversight practices. Treat administrator selection, TPA/ASO monitoring, and IDR Gateway readiness as fiduciary functions: document the decision-making process, update committee charters and meeting minutes, and confirm the plan’s fiduciary liability insurance and indemnification provisions address IDR-related exposures.
6. Update vendor agreements. Amend TPA, ASO and business associate agreements to require timely IDR Gateway registration, IDR Registry compliance (for payers), and standardized code usage, with reporting obligations back to the plan.
7. Train staff. Brief HR, benefits and claims personnel handling out-of-network claims on the new open-negotiation notice process (30-business-day clock, 15-business-day response deadline) and the accelerated 5-business-day eligibility determination timeline.
8. Keep using the current web forms for now. Continue submitting disputes through the existing Federal IDR web forms until CMS releases IDR Gateway sign-up details and formally transitions the process.

Why This Matters

For ERISA-covered group health plans, decisions about how the plan manages No Surprises Act disputes — including who administers the IDR Gateway account and how vendors are monitored — implicate fiduciary duties of prudence and loyalty. Missing the administrator sign-up window, failing to confirm a TPA’s Gateway registration, or continuing to rely on procedures that do not reflect the new fee, batching, and timing rules could expose plans and their fiduciaries to processing delays, forfeited dispute rights, or claims of fiduciary breach. Because CMS is rolling these changes out in phases tied to forthcoming guidance, plans, fiduciaries and their advisors should treat this as a standing agenda item for plan committee meetings through the end of 2026.

Part 2 — Audit & Fix Your 2026 NSA Compliance and Out-of-Network Cost Assumptions

While preparing for the IDR Gateway and other future changes, plan sponsors and fiduciaries should also use the fall renewal and budgeting cycle to prudently audit and evaluate their out-of-network benefit design, reference based or other pricing assumptions and models and NSA and other out-of-network claims compliance and processes.

Aside from providing invaluable insights about plan cost and liability drivers and opportunities to mitigate current and future liabilities arising from NSA covered and other out-of-network claims, plan sponsors and officers, directors or employees serving as named fiduciaries or functioning performing these responsibilities bear fiduciary responsibility for arranging and verifying the prudent performance of these responsibilities under ERISA Section 404.\

In fact, many plan sponsors or their officers, directors or management employees will be horrified to discover that due to less than optimal provisions in their usually vendor provided plan documents and administrative services agreements, the plan sponsor, an officer, director or employee of the plan sponsor or both is the fiduciary responsible under ERISA Section 404, not the third party administrator or other plan vendor, for prudently ensuring proper handling of these responsibilities and the resulting added costs and liabilities resulting from their mishandling.

Emerging litigation and IDR performance data also strongly suggests that many plans, their sponsors and fiduciaries conducting these assessments will be unhappily surprised by the results of their investigation. Emerging litigation, IDR performance data and other emerging information suggests many health plans have and continue incurring significantly and arguably unnecessarily higher than projected costs and liabilities due to their plan’s design and administration in reliance upon reference based pricing models rendered unsustainable by the NSA, bungled handling of NSA responsibilities by plan vendors, and other NSA compliance and administration defects rather than provider abuse of the NSA process often bemoaned by plan vendors and insurers.

At minimum, this review within the scope of attorney-client privilege generally should evaluate:

• Review 2026 and 2027 plan documents and services agreements to confirm the identity of the party assigned fiduciary responsibility for proper handling of NSA and other out-of-network NSA and other claims handling processes and that the those assigned fiduciary responsibility in operation actually are handling these actions prudently in accordance with their designated responsibility and the NSA rules.
• Assess how well the plan, its fiduciaries and its vendors actually complied with NSA procedural requirements during the 2026 plan year and any heightened cost or liability exposures resulting from any suboptimal performance.
• Assess the likelihood that the plan is or between now and year end is likely to be exposed to liability for existing or potential NSA arbitration awards, lawsuits, or penalties from unpaid NSA awards on out-of-network claims, consult experienced legal counsel about steps that the plan should take to minimize potential forfeiture of stop loss coverage for these amounts and other actions that may help resolve and mitigate these liabilities
• If the assessment reveals that the plan or its fiduciaries are exposed to increased costs, claims or fiduciary liabilities, or penalties due to service providers’ mishandling of NSA out-of-network negotiations, arbitration or other responsibilities, consult with experiencd legal counsel about potential avenues of recourse against plan service providers or others for
• Evaluate actual 2026 out-of-network claim costs against the 2026 reference based pricing and other claims and cost projections relied upon in formulating 2026 plan year pricing and cost forecasts

Step 1: Audit Procedural Compliance

For each out-of-network claim that reached the NSA process during the 2026 plan year, confirm that the plan or its TPA:

• Sent timely notice of the qualifying payment amount (QPA) and other required disclosures with the initial payment or denial;
• Opened and responded to open negotiation within the required 30-business-day window (now triggered by portal submission under the final rule);
• Prepared complete, timely, and well-supported IDR offers and written arguments — including QPA methodology and any additional credible information — rather than default or boilerplate submissions;
• Paid or collected payment on IDR determinations within the required timeframe; and
• Calculated participant cost-sharing using the QPA rather than provider billed charges.

Gaps in any of these areas are not just paperwork problems. As discussed below, incomplete or untimely IDR responses are now a documented, widespread driver of adverse — and expensive — outcomes.

Step 2: Compare Actual 2026 OON Costs to Your Projections

Ask your actuary, broker, TPA or reference-based pricing (RBP) vendor to reconcile actual 2026 plan-year OON claim costs (including IDR administrative fees, negotiated settlements, and arbitration awards) against the assumptions used to build the 2026 budget and the 2027 renewal projection. Where actual costs materially exceeded projections, plans should press their vendors to explain why — and should not simply accept “providers are gaming the system” as the answer without testing it against the data below.

Step 3: Diagnose the Variance

In Solutions Law Press, Inc.’s experience, unfavorable OON cost variances typically trace to one or both of two root causes, both of which are increasingly well-documented:

(1) Unreasonably low pricing assumptions. CMS’s own published IDR performance data show that the prevailing (winning) offer exceeded the qualifying payment amount (QPA) in approximately 88% of payment determinations in the first half of 2025 and approximately 87% of determinations in the second half of 2025 — see CMS, Federal IDR PUF Supplemental Background, Jan.–June 2025 and CMS, Federal IDR PUF Supplemental Background, July–Dec. 2025. If the QPA is exceeded in roughly nine out of ten decided disputes, a plan, TPA, or reference-based pricing (RBP) vendor that is still pricing anticipated out-of-network exposure primarily off of QPA figures or “usual and customary” tables — without reasonably accounting for actual IDR outcome data — is likely understating 2026 and 2027 out-of-network cost projections.

(2) Administrative deficiencies. The same official CMS reports show providers prevailing in approximately 88% of decided disputes in the first half of 2025 and approximately 85% in the second half of 2025; default decisions (meaning a party, often the plan or its TPA, failed to timely or adequately participate) at 22% in the first half of 2025, improving to 17% in the second half; non-initiating parties (typically plans/issuers) raising eligibility challenges in 40% and 42% of disputes, respectively; and only 37% of determinations issued within the required 30-business-day timeframe in the first half of 2025, improving to 62% in the second half. See CMS, Federal IDR PUF Supplemental Background, Jan.–June 2025 and CMS, Federal IDR PUF Supplemental Background, July–Dec. 2025; see also the full set of CMS Independent Dispute Resolution reports. Every default decision, missed deadline, or incomplete submission is a preventable cost. Plans should ask their TPA for a log of every 2026 dispute showing eligibility challenges raised, response timeliness, and outcome, to see whether their own vendor’s administration is contributing to the losses.

The Litigation Backdrop: Courts Are Rejecting the “Provider Fraud” Narrative

Several major insurers have recently tried to recharacterize high-volume IDR activity as fraud rather than a symptom of underpricing. Beginning in 2026, Anthem Blue Cross, Blue Cross Blue Shield of Texas, Aetna, and a Blue Cross Blue Shield of Georgia affiliate of Elevance Health each sued healthcare providers and IDR-support companies (including HaloMD and Radiology Partners), alleging the defendants ran a coordinated scheme — through federal RICO, wire fraud, and related state-law claims — to systematically flood the IDR process with disputes and extract improper arbitration awards. Federal courts have now rejected each of these suits at the pleading stage (one is currently on appeal):

• Anthem Blue Cross Life & Health Ins. Co. v. HaloMD LLC, No. 8:25-cv-01467 (C.D. Cal., order granting motion to dismiss entered Apr. 9, 2026) — dismissed as an “end run” around the NSA’s limits on judicial review of IDR determinations. See PACER, the federal judiciary’s official case-record system.
• Blue Cross Blue Shield of Texas v. HaloMD LLC, No. 5:25-cv-00132 (E.D. Tex., order dismissing with prejudice entered May 22, 2026) — dismissed as “no more than a collateral attack” on IDR awards. See PACER.
• Aetna Health Inc. v. Radiology Partners Inc., No. 3:24-cv-01343 (M.D. Fla., order granting motion to dismiss entered Apr. 16, 2026; notice of appeal filed May 6, 2026 — currently pending before the Eleventh Circuit). See PACER.
• Blue Cross Blue Shield Healthcare Plan of Georgia, Inc. v. HaloMD, Inc., No. 1:25-cv-02919 (N.D. Ga., order dismissing with prejudice entered July 10, 2026) — the court found it “far more plausible” that the insurer “engages in a consistent practice of submitting lowball offers” than that thousands of providers conspired to defraud it. See GovInfo.gov (U.S. Government Publishing Office) case file and PACER.

Date	What Happens
April 2022	Federal IDR process launched under the No Surprises Act.
May 28, 2026	HHS, DOL, Treasury and OPM finalize the “Federal Independent Dispute Resolution Operations” rule.
June 4, 2026	Final rule published at 91 Fed. Reg. 33900 (Doc. No. 2026-11140).
~June 11, 2026	Reduced $15 per-party administrative fee takes effect (5 business days after publication).
August 3, 2026	General effective date of the final rule (91 Fed. Reg. 33900).
September 15, 2026	All potential IDR Gateway users may begin creating accounts; organizations should have selected their administrator(s) by this date.
90 days after related CMS guidance/functionality announcements	Phased rollout of batching changes, portal-based open negotiation/eligibility processing, and the IDR Registry.
Late 2026	Federal IDR web forms are retired; the IDR Gateway becomes the required platform for managing disputes.

In each case, the courts held that Congress deliberately shielded IDR determinations from broad collateral judicial review, and that insurers cannot use RICO or similar theories to relitigate arbitration outcomes they simply dislike. (The Aetna/Radiology Partners dismissal is on appeal, so it is not yet final.) Read together with the official CMS performance data above, these rulings support a different conclusion than “provider abuse”: that a meaningful share of the OON cost pressure plans are seeing may reflect payers’ and TPAs’ own pricing and administrative shortfalls, not a corrupted dispute process. Plan fiduciaries should not assume unfavorable IDR experience is explained away by “provider gaming” without independently testing that assumption against their own vendor’s performance data. Federal district court filings are maintained in the judiciary’s PACER system; full copies of the pleadings and orders cited above can be retrieved there by case number, and the Georgia order is additionally available through GovInfo.gov.

Exposure Beyond Higher Claim Costs

NSA compliance gaps do more than inflate OON spend. They can expose the plan, its fiduciaries and its administrators to:

• Benefits and fiduciary-breach litigation. Participants can bring claims under ERISA § 502(a), 29 U.S.C. § 1132(a) over mishandled cost-sharing, wrongful denials, or QPA miscalculation, and fiduciaries can face breach-of-duty claims for failing to prudently monitor how the plan and its TPA are administering NSA obligations.
• Regulatory enforcement and civil penalties. DOL’s Employee Benefits Security Administration administers and helps enforce No Surprises Act requirements for ERISA-covered group health plans — see DOL, Surprise Billing and Price Transparency (EBSA). Plans under DOL investigation also face independent exposure for recordkeeping and document-production failures: under ERISA § 502(c)(6), civil penalties for failing to timely furnish documents the Department requests run up to $195 per day, not to exceed $1,956 per request — see Federal Register, ERISA Civil Penalties Inflation Adjustments for 2025 — on top of any substantive NSA violations found.
• Loss of stop-loss or other reinsurance recovery. Most stop-loss and reinsurance contracts condition reimbursement on the plan and its TPA properly and timely administering claims (including NSA negotiation and IDR deadlines) and on timely submission of proof of loss and stop-loss claims within the policy’s contractual deadlines. Administrative missteps or late claim filings driven by NSA non-compliance can jeopardize specific or aggregate stop-loss recovery — compounding, rather than offsetting, the plan’s excess OON costs. [This point reflects Solutions Law Press, Inc.’s general observation of common stop-loss contract terms, not a specific ruling or study — plans should confirm the actual terms of their own stop-loss contract.]
• Vendor and contractual exposure. Poor TPA or RBP vendor performance uncovered by an audit may support renegotiating fees, invoking indemnification provisions, or replacing a vendor — but only if the plan has documented the deficiency.
• Reputational and participant-relations costs. Underpriced or mishandled OON claims frequently surface as balance-billing complaints, appeals, and participant dissatisfaction, even where the plan is not ultimately liable.

Recommended Audit and Action Steps

1. Commission a 2026 NSA compliance audit covering negotiation timeliness, IDR response completeness and timeliness, QPA calculation methodology, notice content, and payment timing.
2. Reconcile actual 2026 OON claim costs (including administrative fees and IDR awards) against the assumptions used for the 2026 budget and 2027 renewal, and require material variances to be explained.
3. Request a full 2026 IDR dispute log from your TPA/ASO vendor — disputes initiated, eligibility challenges raised, defaults, timeliness of responses, and outcomes relative to QPA — to identify systemic administration issues.
4. Benchmark your plan’s or vendor’s QPA/reference-based-pricing methodology against actual contracted-rate and IDR outcome data, and challenge assumptions that do not reasonably account for NSA experience.
5. Review stop-loss and reinsurance contracts for claim-filing deadlines and proper-administration conditions, and confirm your TPA is meeting them for NSA-related claims.
6. Document the audit, findings, and any corrective action plan in fiduciary committee minutes as part of the plan’s ongoing prudent-process record.
7. Engage counsel to assess potential fiduciary-breach exposure, vendor indemnification rights, and recovery options where the audit reveals material vendor deficiencies.

For Help or More Information

The author of this update, Cynthia Marcotte Stamer has decades of experience advising and assisting health industry clients to design, audit, and defend their organizations and practices including conducting audits and investigations, designing and updating compliance and risk management programs, responding to government investigations, conducting transaction, governance, and other due diligence, and assisting with other legal and operational compliance and risk management and legislative and regulatory affairs. She is available to assist your organization in assessing the impact of these developments and navigating the compliance and strategic steps that follow. For more information about these or other health care, managed care and other health benefits, or other health industry laws or concerns, contact Ms. Stamer via e-mail or via telephone at (214) 452 -8297.

About the Author

Cynthia Marcotte Stamer is an American College of Employee Benefits Counsel and a Martindale-Hubble “AV-Preeminent” (Top 1%) attorney and advisor board certified in labor and employment law by the Texas Board of Legal Specialization peer peer celebrated as “Top Rated Lawyer” and “LEGAL LEADER™ “Top Rated Lawyer” and “Best Lawyer” for her work in ERISA & Employee Benefits Law, Health Care Law, Labor and Employment Law, and Business and Commercial Law.

Nationally recognised for her decades of leading edge health and other employee benefits and insurance, compensation, human resources and other management work, public policy leadership and advocacy, coaching, teachings, and publications, Ms. Stamer is well known for her decades of pragmatic, leading edge work, scholarship and thought leadership on health benefit and other health and managed care, privacy and data security and other employee benefit, insurance, and health industry legal, public policy and operational concerns. 

Ms. Stamer’s work throughout her career has focused heavily on working with health care and managed care, health and other employee benefit plan, insurance and financial services and other public and private organizations and their technology, data, and other service providers and advisors domestically and internationally with legal and operational compliance and risk management, performance and workforce management, regulatory and public policy and other legal and operational concerns.  As a a key focus of this work, she has continuously and extensively worked with domestic and international health plans, their sponsors, fiduciaries, administrators, and insurers; managed care and insurance organizations; third party administrators and other health benefit service providers; hospitals, health care systems and other health care providers, accreditation, peer review and quality committees and organizations; billing, utilization management, management services organizations, group purchasing organizations; pharmaceutical, pharmacy, and prescription benefit management and organizations; consultants; investors; EMR, claims, payroll and other technology, billing and reimbursement and other services and product vendors; products and solutions consultants and developers; investors; managed care organizations, self-insured health and other employee benefit plans, their sponsors, fiduciaries, administrators and service providers, insurers and other payers, health industry advocacy and other service providers and groups and other health and managed care industry clients as well as federal and state legislative, regulatory, investigatory and enforcement bodies and agencies.

Her experience includes more than 35 years of leading edge work for employer and other plan sponsors, plans and their fiduciaries, insurers, third party administrators, health care clearinghouses and other health care, insurance and other data and technology providers, and others on health and other employee benefits design, administration, compliance, and policy including decades of work on fiduciary compliance and risk management; eligibility, coverage and other plan mandates; administrative simplification and transparency; PBM, pharmacy and pharmaceutical management and regulation; surprise billing and other non-par provider; direct provider, vendor and other credentialing, contracting and management; and other managed care and insurance; high deductible, minimum or level premium, captive and other non traditional funding; and agency and private audits, investigations and enforcement; and other insured and self-insured health benefit contracting, design, administration, regulation, fiduciary and other liability managment, and other design, compliance, risk management, defense, and operations solutions.

She also has extensive experience helping health care systems and organizations, group and individual health care providers, health plans and insurers, health IT, life sciences and other health industry clients prevent, investigate, manage and resolve  sexual assault, abuse, harassment and other organizational, provider and employee misconduct and other performance and behavior; manage Section 1557, Section 504, Civil Rights Act and other discrimination and accommodation, and other regulatory, contractual and other compliance; vendors and suppliers; contracting and other terms of participation, medical billing, reimbursement, claims administration and coordination, Medicare, Medicaid, CHIP, Medicare/Medicaid Advantage, ERISA and other payers and other provider-payer relations, contracting, compliance and enforcement; Form 990 and other nonprofit and tax-exemption; fundraising, investors, joint venture, and other business partners; quality and other performance measurement, management, discipline and reporting; physician and other workforce recruiting, performance management, peer review and other investigations and discipline, wage and hour, payroll, gain-sharing and other pay-for performance and other compensation, training, outsourcing and other human resources and workforce matters; board, medical staff and other governance; strategic planning, process and quality improvement; meaningful use, EMR, HIPAA and other technology,  data security and breach and other health IT and data; STARK, ant kickback, insurance, and other fraud prevention, investigation, defense and enforcement; audits, investigations, and enforcement actions; trade secrets and other intellectual property; crisis preparedness and response; internal, government and third-party licensure, credentialing, accreditation, HCQIA and other peer review and quality reporting, audits, investigations, enforcement and defense; patient relations and care;  internal controls and regulatory compliance; payer-provider, provider-provider, vendor, patient, governmental and community relations; facilities, practice, products and other sales, mergers, acquisitions and other business and commercial transactions; government procurement and contracting; grants; tax-exemption and not-for-profit; privacy and data security; training; risk and change management; regulatory affairs and public policy; process, product and service improvement, development and innovation, and other legal and operational compliance and risk management, government and regulatory affairs and operations concerns. to establish, administer and defend workforce and staffing, quality, and other compliance, risk management and operational practices, policies and actions; comply with requirements; investigate and respond to Department of Insurance, Board of Medicine, Health, Nursing, Pharmacy, Chiropractic, trucking, alcohol and firearm, and other licensing agencies, Department of Aging & Disability, FDA, Drug Enforcement Agency, OCR Privacy and Civil Rights, Department of Labor, IRS, HHS, DOD, FTC, SEC, CDC and other public health, Department of Justice and state attorneys’ general and other federal and state agencies; JCHO and other accreditation and quality organizations; private litigation and other federal and state health care industry actions: regulatory and public policy advocacy; training and discipline; enforcement;  and other strategic and operational concerns.

Former lead advisor to the Government of Bolivia on its Social Security Privatization reform, miss Stamer also has extensive legislative and regulatory affairs experience on federal, state and international employee benefits, healthcare, workforce, education, insurance, data privacy and security, antitrust, and other regulations and reforms.

In addition, Ms. Stamer contributes her time and leadership to numerous policy, professional, civil and other organizations, Ms. Stamer currently or previously served as the Scribe leading annual agency meetings on HIPAA and other issues with the Department of Health and Human Services; leadership Council Representative, speaker, author and faculty lead for the American Bar Association (“ABA”) Joint Committee on Employee Benefits; the ABA International Section International Employment Law Committee and International Life Sciences Committee Chair; the ABA Tort Trial and Insurance Practice Section Medicine and Law Committee Chair and Employee Benefits and Worker’s Compensation Committees Vice Chair; the ABA Health Law Section Managed Care & Insurance Interest Group Chair and Risk Management Interest Group Chair; the ABA RPTE Employee Benefits & Other Compensation Group Chair and Welfare Benefit, Fiduciary Responsibility, and Plan Terminations and Transactions Committees Chair; Vice President and Executive Director of the North Texas Health Care Compliance Professionals Association; a Southwest Benefits Association Board Member; a SHRM Consultants National and Region IV Board Chair; WEB National Board Member and Dallas Chapter President; National Kidney Foundation of North Texas Board Member and Compliance Chair; Richardson Development Center (now Warren Center) for Children Early Childhood Intervention Agency Board President; a North Texas United Way Long Range Planning Committee Member; and other leadership involvement in a broad range of other professional and civic organizations.

Author of hundreds of highly regarded works on health and other benefits, human resources, health care, insurance, data privacy and security and other related concerns, examples of these publications include “Transparent PBM Contracting,” “ACOs, Direct Contracting: Legal & Practical Challenges For Employers, Providers & TPAs,” “The Medicare Advantage Contracting Manual,” “Third Party Administrator (TPA) Contracting Principles and Strategies and a multitude of other publications and presentations. 

For more information about Ms. Stamer or her health industry and other experience and involvements, see www.cynthiastamer.com or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

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