The U.S. Supreme Court has declined to review a Fifth Circuit decision addressing whether the No Surprises Act permits providers to bring private lawsuits to enforce independent dispute resolution (IDR) awards against insurers. The Court’s rejection leaves intact a June 2025 ruling holding that providers may not seek to enforce IDR awards through private court actions.
In Guardian Flight LLC v. Health Care Service Corp., the Fifth Circuit concluded that Congress intended enforcement of the No Surprises Act to occur through administrative penalties rather than private litigation. The Fifth Circuit panel also rejected related ERISA claims, reasoning that providers lack standing to bring derivative ERISA claims because the beneficiaries could not suffer a concrete injury as the No Surprises Act shields beneficiaries from liability for any out-of-network costs.
By declining to take up the case, the Supreme Court leaves unresolved broader questions about how providers can compel payment of IDR awards when insurers allegedly fail to pay. The decision leaves continued uncertainty surrounding the federal IDR framework and may prompt providers to reassess their reliance on the IDR process.
A copy of the petition is available here.
