UHS · 10-Q · 2026Q2 · Full report

Surprise Billing Regulation

UNIVERSAL HEALTH SERVICES INC · 2026-08-07 · Importance 29 · Surprise 24 · In source text

The Consolidated Appropriations Act of 2021 and implementing rules issued by HHS, the Department of Labor and the Department of the Treasury restrict patient balance billing for certain emergency, out-of-network ancillary and air-ambulance services. The rules limit hospital-based physicians’ ability to obtain normally higher out-of-network payments in specified circumstances. UHS has consequently increased subsidies to those physicians or replaced their services at higher cost.

Key facts

• On June 4, 2026 HHS, the Department of Labor, the Department of the Treasury, and OPM issued a final rule intended to improve the functioning of the federal IDR process. source
• Portions of CMS regulations and guidance implementing the IDR process have been vacated by a federal district court causing CMS to pause and resume IDR process operations on several occasions. source
• A district judge in the Eastern District of Texas invalidated portions of the rule governing aspects of the IDR process on February 28, 2022. source
• The government issued a final rule on August 19, 2022 eliminating the rebuttable presumption in favor of the qualifying payment amount by the IDR entity and providing additional factors the IDR entity should consider. source
• On September 30, 2021 the Department of Labor, the Department of the Treasury, and OPM released an interim final rule entitled “Requirements Related to Surprise Billing; Part II.” source

Impact estimates